Interactive Brokers LLC
Interactive Brokers Corp

REGULATION BEST INTEREST DISCLOSURE

Regulation Best Interest ("Reg BI") establishes a standard of conduct for broker-dealers and natural persons who are associated persons of a broker-dealer when making a recommendation of any securities transaction or investment strategy involving securities (including account recommendations) to a retail customer.

If Reg BI applies, a broker-dealer must act in the best interest of a retail customer when making a recommendation and at the time the recommendation is made.

Interactive Brokers LLC and Interactive Brokers Corp (collectively "IBKR" or "we" or "us") do not recommend securities transactions or investment strategies involving securities (including account type recommendations) to its customers and, accordingly, Reg BI does not apply to IBKR. However, should any information or service offered by IBKR (including any customer communications or tools or features of the IBKR trading systems) be construed as a recommendation to a retail customer, these disclosures describe (1) the scope and terms of our relationship with retail customers and (2) conflicts of interest associated with information or services provided by the Firm.

Introduction

IBKR is providing this document to enhance the quality and transparency of our relationship with our customers. This document discloses material facts about the scope and terms of the relationship between IBKR and its retail customers.

About IBKR

Interactive Brokers LLC ("IB LLC") is an online broker that provides self-directed trade execution and clearing services. IB LLC offers its customers the ability to buy and sell investment products like stocks, options, ETFs, bonds, mutual funds, and other financial products in a brokerage account.

Interactive Brokers Corp ("IB Corp") is an affiliate of IB LLC and a registered broker-dealer. IB Corp does not maintain any customer accounts or hold client assets. Although retail customers open accounts with IB LLC and not IB Corp, IB Corp may play a role in executing your orders.

IB Corp employs U.S. sales representatives and acts as an executing broker for IB LLC by routing IB LLC customer orders to certain exchanges. IB Corp may also facilitate the internalization of non-directed whole share customer order flow for clients of IB LLC, as well as facilitate IB LLC fractional share trading.

IB LLC and IB Corp are broker-dealers registered with the Securities and Exchange Commission ("SEC"), Financial Industry Regulatory Authority ("FINRA"), and various exchanges. Accordingly, they are subject to the Securities Exchange Act of 1934 (the "Exchange Act") and the rules promulgated thereunder, and is regulated by the SEC, the Financial Industry Regulatory Authority ("FINRA"), and other self-regulatory organizations and exchanges of which the firm is a member.

Disclosure Obligation

This section contains the material facts about the scope and terms of IBKR's relationship with retail customers. This includes a disclosure regarding: (1) the capacity in which IBKR and/or its representatives act; (2) the material fees and costs the customer may incur; and (3) the type and scope of the services to be provided, including any material limitations on recommendations that could be made to the retail customer if IBKR were deemed to have made a recommendation.

This section also contains disclosures regarding material facts relating to conflicts of interest if IBKR were deemed to have made a recommendation.

Material facts relating to the scope and terms of our relationship with retail customers.

1. Capacity.

   IBKR acts as a broker-dealer with respect to any recommendations and executions of your trades and may execute trades on an agency or riskless principal basis. IB Corp may also trade on a principal basis for the limited purposes of facilitating fractional trading by its clients. We are not an investment advisor.

2. Material Fees and Costs That Apply to Your Transactions, Holdings, and Accounts.

   The principal fees, disbursements, and costs that a customer may incur or receive in exchange for our brokerage services are: (i) Commissions; (ii) Exchange, Regulatory, and Clearing Fees; (iii) Subscription Service Fees; (iv) Interest and Financing Costs; (v) Stock Loan Disbursements; (vi) Payment for Order Flow; (vii) Affiliate Investment in Exchanges; and (viii) Other Fees and Costs. IB LLC does not currently charge clients minimum activity fees or require minimum equity to open an account, although there are minimum equity requirements for certain trading strategies (e.g., trading on margin or uncovered options) as noted below in Section 3. As previously noted, IB Corp does not have customer accounts.

   Fees and costs will vary depending on the products the customer elects to trade, the customer's volume of trading, and the services and pricing plan the customer selects. Customers will pay fees and costs whether they make or lose money on their investments, and this will reduce any profits from investments over time.

   We do not compensate employees based on the number of trades a client places or the amount of fees a customer pays.

   Here is an overview of our fees and costs:

   1. Commissions: Commissions are transaction-based fees charged by brokers. IB LLC offers tiered, fixed and zero-commission pricing plans. Commissions charged will vary depending on the pricing plan that a client selects and the products a client trades. Please see ibkr.com/commissions for additional details
   2. Exchange, Regulatory, and Clearing Fees: Exchanges, regulators and clearing houses may charge IBKR fees when IBKR executes orders for you. These fees may be charged to a customer's account in addition to commissions depending on the commission structure that the customer selects and the products the customer trades. Exchange, Regulatory, and Clearing fees charged to the customer may be greater than the corresponding fees paid by IBKR (e.g., IBKR may receive aggregate volume discounts that are not passed on to the customer). Please see ibkr.com/commissions for additional details.
   3. Subscription Service Fees: IBKR offers access to third-party research, realtime streaming market data, and other subscription services. If a customer elects to subscribe to any of these services, they may be charged to cover the cost. Additional details can be found at ibkr.com/researchandnews and ibkr.com/marketdata.
   4. Interest and Financing Costs: IB LLC may offer eligible customers financing, including allowing them to borrow on margin or to borrow stock for purposes of short selling. These services have corresponding costs, which are charged to the customer's account in the form of margin loan interest and stock borrow fees. Please see www.ibkr.com/interest for additional details.
   5. Stock Loan Disbursements: IBKR eligible account holders may enroll in the Stock Yield Enhancement Program ("SYEP"). IBKR clients enrolled in SYEP may earn additional income on their fully-paid shares by lending those shares to IBKR for lending to short sellers that pay to borrow them. IBKR may generate revenue from shares lent through the SYEP program. Please see www.ibkr.com/syep for additional details.
   6. Payment For Order Flow (PFOF): IBKR may receive payment in the form of commissions or other payments from the liquidity providers of your executions. Payments may be in the form of rebates provided by an exchange, or rebates pursuant to the maker-taker model provided by some exchanges. Please see the Order Routing and Payment for Order Flow Disclosure for additional details.
   7. Internalization of Customer Order Flow: IBKR may internalize non-directed whole share customer order flow through an affiliate. The internalization of customer orders is intended to provide the opportunity for improved execution quality (i.e., increased price improvement) and/or reduced execution costs without reducing execution quality. The internalization of a customer order may enable the IBKR affiliate to generate a trading profit by trading as principal. Customers have the option to opt out of internalization of the whole-share portions of their stock orders; customers cannot opt out of internalization for the fractional-share portion of any order they submit.
   8. Affiliate Investments in Exchanges: An affiliate or affiliates of Interactive Brokers LLC own(s) a minority investment in the Boston Options Exchange Group LLC, which operates the BOX Options Exchange. While IBKR's routing systems do not consider this as a factor when determining the optimal marketplace to route customer orders, IBKR may ultimately share in profits earned by the exchange. Please see the Order Routing and Payment for Order Flow Disclosure for additional details.
   9. Other Fees and Costs: IB LLC offers products and services in addition to online trading. Such products and services include, but are not limited to, processing corporate actions and dividends, cash movements, and securities transfers. These services may be offered at additional cost. Please see www.ibkr.com/otherfees for additional details.

   While the above list includes some of the more common fees, costs, and payments that clients may encounter, it is not exhaustive. For complete details of services provided by IBKR and corresponding fees and costs, please visit www.ibkr.com. Commissions and other fees are based on the trading customers conduct and the services that customers choose.

   Additional information regarding specific commissions and fees is available at ibkr.com/commissions and ibkr.com/otherfees.

   Separately, additional fees may apply for certain products. For example, if you purchase mutual funds, there may be a management fee that is charged by the fund manager and subtracted from the amount of your fund investment. The specific fees for these products vary by product and are described more fully on our website at ibkr.com/products.

3. Type and Scope of the Services to be Provided.

IB LLC is an online broker that provides self-directed trade execution and clearing services. IB LLC offers eligible customers the ability to buy and sell investment products like stocks, ETFs, options, bonds, mutual funds, and other financial products in a brokerage account.

Neither IB LLC nor IB Corp employs brokers to manage customer accounts or make recommendations as to whether a customer should buy, sell or hold investment products. We do not monitor the performance of customer accounts for purposes of recommending changes in your investments. or providing recommendations or advice to you. We do monitor customer accounts for our purposes, such as compliance with applicable regulations and to ensure that the customer account does not present undue risk to IBKR. We do provide tools to assist customers with monitoring their portfolio holdings and risk, or for informational or educational purposes.

We do not provide investment advice or make recommendations to customers or investors on account types or pricing plans. All of our employees are prohibited from providing such recommendations or advice.

We deliver electronic confirmations of each trade executed in customers' accounts. Customers have access to electronic account statements that are posted daily, monthly, quarterly, and annually.

We do not have discretionary trading authority over customer accounts other than accepting unsolicited not-held orders (where customers give us price and time discretion). We do not offer proprietary products. There are no account minimums or other requirements to open or maintain a brokerage account with us. Certain products and services may have minimum equity or other eligibility requirements. For example, customers utilizing margin, trading certain products types or establishing certain types of positions must meet minimum equity requirements, as well as account eligibility requirements that take into account a customer's financial profile, investment objectives and experience.

For more details on services offered by IBKR, please see www.ibkr.com/products or contact IBKR here.

Limitations regarding ESG material, our approach, and related risks.

In the course of providing educational and informational material, IBKR may identify and describe specific securities (e.g., IBKR may describe a security's performance on certain environmental, social and governance ("ESG") criteria selected by a customer using IBKR's IMPACT app). These educational and informational materials do not constitute recommendations. However, if any such communication was construed to be a recommendation, IBKR reasonably believes any security for which it has provided ESG information is suitable for at least some investors because IBKR provides this information only for products that are available for purchase to customers with our most conservative investment objective of Preservation of Capital. This investment objective limits clients to trading stocks, bonds, warrants or mutual funds in cash accounts, although ESG information is further limited to single name listed securities. Further, IBKR reasonably believes that if a customer were to effect a transaction based on the ESG performance information that IBKR provides about a security, such transaction would be suitable for that customer because each IBKR customer indicates that; to the extent their ESG criteria selections are inconsistent with other investment objectives or considerations; the customer intends for IBKR to provide information based on the customer's ESG criteria selection. When IBKR provides ESG information about a specific security, it does not take into account the potential financial effects of trading in the security. Trading in any security could lead to financial losses in a customer's portfolio and a decision to invest based on educational information could result in a customer's portfolio underperforming a different portfolio or the market as a whole. Replacing securities in a customer's portfolio with securities for which IBKR has provided educational information may result in immediate or future financial losses.

4. Material Facts Relating to Conflicts of Interest Associated with a Recommendation.

As stated above, IBKR does not provide recommendations to our clients. We provide certain educational and informational material about specific securities. When IBKR provides educational material about a specific security, it does not have any financial interest in that security resulting from any market making, underwriting, or proprietary trading activity because we do not offer proprietary investment products, engage in market making or underwriting activities, or maintain proprietary positions for the purpose of the firm's own investment. As stated above, IBKR may occasionally act as principal for the purpose of facilitating trading by its clients, such as fractional share trading.

However, should any service offered by us (including any customer communications or tools or features of our trading systems) be construed as a recommendation, we want our customers to be aware of the ways we make money and the potential for those arrangements to create conflicts of interest related to their brokerage accounts.

As discussed above in Section 2, we are compensated in a variety of ways, including charging commissions and/or receiving payment for order flow on customer self- directed trading, as well as charging interest on financing, receiving interest on uninvested cash in customer accounts, and charging subscription fees for optional services that a customer decides to engage in.

The following disclosures are intended to explain the potential conflicts of interest that IBKR may have with its customers:

1. Commissions. For certain financial transactions and depending on the commission plan chose by the customer, we receive a commission when we execute transactions that result in the purchase or sale of a security. Therefore, if we receive a commission under your plan, the more you trade with us, the more money IBKR receives. A commission is typically paid at the time of the transaction and can reduce the amount available to invest or can be charged directly against an investment. Commissions may differ based on the trading volume of the client. For more information about our commissions, please visit ibkr.com/commissions.
2. Margin Interest. We charge interest on financing. Therefore, the larger the debit balance within a brokerage account the more interest that IBKR will earn. Current margin rates may be viewed at www.ibkr.com/margin. Please review the Disclosure of Risks of Margin Trading for more information.

Our employees are compensated through salary and merit-based discretionary bonuses. The bonus component is calculated based on factors including IBKR and individual performance and may include cash and/or IBKR stock that vests over a period of years. They are not compensated directly based on the amount of commissions or fees, performance of customer accounts, the amount of customer assets they service, the products that customers buy or sell, or revenue earned from services or products chosen by customers. However, because they are compensated in part based on IBKR performance, these factors may indirectly affect their compensation.

We mitigate the potential conflicts of interest listed above by applying appropriate policies and controls, including but not limited to the following:

1. No Proprietary Products. We do not create or manage investment products and does not sell, distribute, recommend, market, or otherwise encourage customers to trade in specific products created or managed by IBKR.
2. Compensation Structure. IBKR staff are compensated through salary and merit- based discretionary bonuses. IBKR staff are not directly compensated based on commissions or fees, performance of customer accounts, the amount of customer assets they service, the products that customers buy or sell, or revenue earned from services or products chosen by customers.
3. PFOF Transparency. Pursuant to SEC rules, we make available quarterly reports describing our order routing practices. The reports describe how and where customer orders are routed when customers use IB's Best Execution Order Routing System rather than directing their order to a particular market center. As stated previously, IBKR may receive payment in the form of commissions or other payments from the liquidity providers for these executions. For examples of past reports, click here.
4. Limited Business Operations and No Cross Selling. We do not act as an investor, placement agent, underwriter, distributor, remarketing agent, structurer, securitizer, investment manager, investment advisor, commodity trading advisor, municipal advisor, market maker, or trader and does not produce any proprietary research.

Please see www.ibkr.com/disclosures for additional details.

Additional Information

Additional details about IBKR, and our brokerage services are available at www.ibkr.com. A current copy of the firm's Customer Relationship Summary (Form CRS), is available here.

IBKR does not assign registered representatives to manage client accounts. Our registered representatives are employed by IBKR, which is a broker-dealer and not an investment advisor. Contact us at (312) 542- 6901 or 1 (877) 442-2757 if you have any concerns regarding the service that you receive.

RISK DISCLOSURE STATEMENT FOR FOREX TRADING AND IB MULTI-CURRENCY ACCOUNTS

Rules of the U.S. National Futures Association ("NFA") require Interactive Brokers ("IB") to provide you with the following Risk Disclosure Statement:

RISK DISCLOSURE STATEMENT

OFF-EXCHANGE FOREIGN CURRENCY ("FOREX") TRANSACTIONS INVOLVE THE LEVERAGED TRADING OF CONTRACTS DENOMINATED IN FOREIGN CURRENCY CONDUCTED WITH A FUTURES COMMISSION MERCHANT OR A RETAIL FOREIGN EXCHANGE DEALER AS YOUR COUNTERPARTY. BECAUSE OF THE LEVERAGE AND THE OTHER RISKS DISCLOSED HERE, YOU CAN RAPIDLY LOSE ALL OF THE FUNDS YOU DEPOSIT FOR SUCH TRADING AND YOU MAY LOSE MORE THAN YOU DEPOSIT.

YOU SHOULD BE AWARE OF AND CAREFULLY CONSIDER THE FOLLOWING POINTS BEFORE DETERMINING WHETHER SUCH TRADING IS APPROPRIATE FOR YOU.

1. TRADING IS NOT ON A REGULATED MARKET OR EXCHANGE. YOUR DEALER IS YOUR TRADING PARTNER WHICH IS A DIRECT CONFLICT OF INTEREST. BEFORE YOU ENGAGE IN ANY RETAIL FOREIGN EXCHANGE TRADING, YOU SHOULD CONFIRM THE REGISTRATION STATUS OF YOUR COUNTERPARTY.
   
   The off-exchange foreign currency trading you are entering into is not conducted on an interbank market, nor is it conducted on a futures exchange subject to regulation as a designated contract market by the Commodity Futures Trading Commission ("CFTC"). The foreign currency trades you transact are trades with the futures commission merchant or retail foreign exchange dealer as your Counterparty. WHEN YOU SELL, THE DEALER IS THE BUYER. WHEN YOU BUY, THE DEALER IS THE SELLER. As a result, when you lose money trading, your dealer is making money on such trades, in addition to any fees, commissions, or spreads the dealer may charge.
2. AN ELECTRONIC TRADING PLATFORM FOR RETAIL FOREIGN CURRENCY TRANSACTIONS IS NOT AN EXCHANGE. IT IS AN ELECTRONIC CONNECTION FOR ACCESSING YOUR DEALER. THE TERMS OF AVAILABILITY OF SUCH A PLATFORM ARE GOVERNED ONLY BY YOUR CONTRACT WITH YOUR DEALER.
   
   Any trading platform that you may use to enter off-exchange foreign currency transactions is only connected to your futures commission merchant or retail foreign exchange dealer. You are accessing that trading platform only to transact with your dealer. You are not trading with any other entities or customers of the dealer by accessing such platform. The availability and operation of any such platform, including the consequences of the unavailability of the trading platform for any reason, is governed only by the terms of your account agreement with the dealer.
3. YOUR DEPOSITS WITH THE DEALER HAVE NO REGULATORY PROTECTIONS.
   
   All of your rights associated with your retail forex trading, including the manner and denomination of any payments made to you, are governed by the contract terms established in your account agreement with the futures commission merchant or retail foreign exchange dealer. Funds deposited by you with a futures commission merchant or retail foreign exchange dealer for trading off-exchange foreign currency transactions are not subject to the customer funds protections provided to customers trading on a contract market that is designated by the CFTC. Your dealer may commingle your funds with its own operating funds or use them for other purposes. In the event your dealer becomes bankrupt, any funds the dealer is holding for you in addition to any amounts owed to you resulting from trading, whether or not any assets are maintained in separate deposit accounts by the dealer, may be treated as an unsecured creditor's claim.
4. YOU ARE LIMITED TO YOUR DEALER TO OFFSET OR LIQUIDATE ANY TRADING POSITIONS SINCE THE TRANSACTIONS ARE NOT MADE ON AN EXCHANGE OR MARKET, AND YOUR DEALER MAY SET ITS OWN PRICES.
   
   Your ability to close your transactions or offset positions is limited to what your dealer will offer to you, as there is no other market for these transactions. Your dealer may offer any prices it wishes, and it may offer prices derived from outside sources or not in its discretion. Your dealer may establish its prices by offering spreads from third party prices, but it is under no obligation to do so or to continue to do so. Your dealer may offer different prices to different customers at any point in time on its own terms. The terms of your account agreement alone govern the obligations your dealer has to you to offer prices and offer offset or liquidating transactions in your account and make any payments to you. The prices offered by your dealer may or may not reflect prices available elsewhere at any exchange, interbank, or other market for foreign currency.
5. PAID SOLICITORS MAY HAVE UNDISCLOSED CONFLICTS
   
   The futures commission merchant or retail foreign exchange dealer may compensate introducing brokers for introducing your account in ways which are not disclosed to you. Such paid solicitors are not required to have, and may not have, any special expertise in trading, and may have conflicts of interest based on the method by which they are compensated. Solicitors working on behalf of futures commission merchants and retail foreign exchange dealers are required to register. You should confirm that they are, in fact registered. You should thoroughly investigate the manner in which all such solicitors are compensated and be very cautious in granting any person or entity authority to trade on your behalf. You should always consider obtaining dated written confirmation of any information you are relying on from your dealer or a solicitor in making any trading or account decisions.
   
   FINALLY, YOU SHOULD THOROUGHLY INVESTIGATE ANY STATEMENTS BY ANY DEALERS OR SALES REPRESENTATIVES WHICH MINIMIZE THE IMPORTANCE OF, OR CONTRADICT, ANY OF THE TERMS OF THIS RISK DISCLOSURE. SUCH STATEMENTS MAY INDICATE POTENTIAL SALES FRAUD.

THIS BRIEF STATEMENT CANNOT, OF COURSE, DISCLOSE ALL THE RISKS AND OTHER ASPECTS OF TRADING OFF-EXCHANGE FOREIGN CURRENCY TRANSACTIONS WITH A FUTURES COMMISSION MERCHANT OR RETAIL FOREIGN EXCHANGE DEALER.

PERFORMANCE OF INTERACTIVE BROKERS RETAIL CUSTOMER FOREX ACCOUNTS FOR THE PAST FOUR CALENDAR QUARTERS:

The table below sets forth the percentage of non-discretionary retail forex customer accounts maintained by Interactive Brokers LLC that were profitable and unprofitable for the past four calendar quarters. The accounts were identified and these statistics were calculated according to the definitions and interpretations set forth by the CFTC and NFA¹

PAST PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS.

FURTHER INFORMATION PROVIDED BY INTERACTIVE BROKERS:

1. Overview: Interactive Brokers Multi-Currency enabled accounts allow IB Customers to trade investment products denominated in different currencies using a single IB account denominated in a "base" currency of the customer's choosing. IB Customers can also use their Multi-Currency enabled accounts to conduct foreign exchange transactions in order to manage credits or debits generated by foreign securities, options or futures trading, to convert such credits or debits back into the Customer's base currency, or to hedge or speculate. IB foreign exchange transactions offered to retail customers are forex spot transactions.
2. Nature of Your Account and Whether SIPC Covers Foreign Currency: Foreign currency trading at Interactive Brokers takes place in a securities account. Your IB securities account is governed by rules of the U.S. Securities and Exchange Commission ("SEC") and the Financial Industry Regulatory Authority. In addition, IB observes the rules of the National Futures Association in connection with foreign currency trading.
   
   Interactive Brokers LLC is a member of the Securities Investor Protection Corporation ("SIPC"). SIPC protects cash and securities held with Interactive Brokers as specified in the Securities Investor Protection Act. SIPC protects cash, including US dollars and foreign currency, to the extent that the cash was deposited with Interactive Brokers for the purpose of purchasing securities. Whether foreign currency in your IB account would be protected by SIPC would depend in part on whether the cash was considered to be deposited with Interactive Brokers for the purpose of purchasing securities. Interactive Brokers expects that at least one factor in deciding this would be whether and the extent to which the customer engages in securities trading in addition to or in conjunction with forex trading, but, as discussed in section 3 above, funds deposited specifically for forex trading have no regulatory protections under NFA rules or CFTC regulations. For further information, you must contact your own legal counsel or SIPC.
   
   Customer money held in the securities account is subject to Securities Exchange Act Rule 15c3-3 governing customer reserve requirements. Although relevant regulations only require computation of the 15c3-3 reserve requirement and associated segregation of customer funds to be performed weekly, IB performs such calculations and segregation on a daily basis.
   
3. General Risk: Customer understands and acknowledges that buying and selling securities, options, futures and other financial products that are denominated in foreign currencies or traded on foreign markets is inherently risky and requires substantial knowledge and expertise. Customers applying for Interactive Brokers Multi-Currency enabled accounts represent that they are aware of and understand the risks involved in trading foreign securities, options, futures and currencies and that they have sufficient financial resources to bear such risks.
4. Customer Responsibility for Investment Decisions: Customer acknowledges that IB representatives are not authorized to provide investment, trading or tax advice and therefore will not provide advice or guidance on trading or hedging strategies in the Multi-Currency enabled account. Customers must evaluate carefully whether any particular transaction is appropriate for them in light of their investment experience, financial objectives and needs, financial resources, and other relevant circumstances and whether they have the operational resources in place to monitor the associated risks and contractual obligations over the term of the transaction. In making these assessments, IB strongly recommends that Customers obtain independent business, legal, and accounting advice before entering into any transactions.
5. Exchange Rate Risk: Exchange rates between foreign currencies can change rapidly due to a wide range of economic, political and other conditions, exposing the Customer to risk of exchange rate losses in addition to the inherent risk of loss from trading the underlying financial product. If a Customer deposits funds in a currency to trade products denominated in a different currency, Customer's gains or losses on the underlying investment therefore may be affected by changes in the exchange rate between the currencies. If Customer is trading on margin, the impact of currency fluctuation on Customer's gains or losses may be even greater.
6. Currency Fluctuation:  When Customer uses the foreign exchange facility provided by IB to purchase or sell foreign currency, fluctuation in currency exchange rates between the foreign currency and the base currency could cause substantial losses to the Customer, including losses when the Customer converts the foreign currency back into the base currency.
7. Nature of Foreign Currency Exchange Transactions Between Customer and IB: When Customer enters into a foreign exchange transaction with IB, IB, as the counterparty to Customer's trade, may effectuate that transaction by entering into an offsetting transaction with one of IB's affiliates, with another customer that enters quotes into IB's system, or with a third party bank (IB's "Forex Providers"). In such transactions, the Forex Provider is not acting in the capacity of a financial adviser or fiduciary to Customer or to IB, but rather, is taking the other side of IB's offsetting trade in an arm's length contractual transaction. Customer should be aware that the Forex Provider may from time to time have substantial positions in, and may make a market in or otherwise buy or sell instruments similar or economically related to, foreign currency transactions entered into by Customer. IB's Forex Providers may also undertake proprietary trading activities, including hedging transactions related to the initiation or termination of foreign exchange transactions with IB, which may adversely affect the market price or other factors underlying the foreign currency transaction entered into by Customer and consequently, the value of such transaction.
8. Prices on the IB Forex Platforms:  The prices quoted by IB to Customers for foreign exchange transactions on IB's IdealPro platform will be determined based on Forex Provider quotes and are not determined by a competitive auction as on an exchange market. Prices quoted by IB for foreign currency exchange transactions therefore may not be the most competitive prices available. For purposes of maintaining adequate scale and competitive spreads, a minimum size is imposed on all IdealPro orders (USD $25,000 as of September 2024 but this is subject to change at any time). Orders below the minimum size are considered odd lots and limit prices for these odd lot-sized orders are not displayed through IdealPro. Retail leveraged forex orders for odd lot-sized orders are generally executed within 1 pip of the best bid and best offer of the Interbank spread (NBBO). However, if the best quote for such orders is more than 1 pip outside of the NBBO, IB will generally route the order to execute against a bank or dealer bid or offer regardless of the order size in order to get an improved price. Customers may also enter a Request for Quote ("RFQ") on the system. IB will charge transaction fees as specified by IB for foreign currency exchange transactions. IB's Forex Providers will try to earn a spread profit on transactions with IB (differential between the bid and ask prices quoted for various currencies).
9. Price Slippage; Order Cancellation and Adjustment: Prices quoted on IB's system generally reflect the prices at which IB's Forex Providers are willing to trade. Prices quoted on IB's system reflect changing market conditions and therefore quotes can and do change rapidly. As such, when a Customer order is received and processed by IB's system, the quote on IB's platform may be different from the quote displayed when the order was sent by Customer. This change in price is commonly referred to as "slippage." IB generally will not execute a Customer order at a certain price unless IB is able to trade at that price against one of IB's Forex Providers.
   
   If Customer sends an order for a forex transaction to IB's system but Customer's requested price is no longer available and therefore the order is non-marketable, IB will not execute the order then but will place it in IB's limit order book in accordance with Customer's time-in-force instructions. Other customers can then trade against this order when it becomes the National Best Bid and Offer ("NBBO") or IB may execute the order if it becomes marketable based on prices received from IB's Forex Providers.
   
   If Customer sends an order for a forex transaction to IB's system and the current price is more favorable for Customer than what Customer requested in the order, the order will generally be executed at the available better price.
   
   Although IB attempts to obtain the best price for Customer orders on forex transactions, because of the inherent possibility of transmission delays between and among Customers, IB and Forex Providers, or other technical issues, execution prices may be worse than the quotes displayed on the IB platform.
   
   To execute your order, Interactive Brokers engages in back-to-back transactions with one or more counterparties. These counterparties on occasion may cancel or adjust forex trades with us in the event of market or technical problems. In these cases we may have to cancel or adjust forex trades that you have executed.
10. Other Risks: There are other risks that relate to trading foreign investment products and trading foreign currencies that cannot be described in detail in this document. Generally, however, foreign securities, options, futures and currency transactions involve exposure to a combination of the following risk factors: market risk, credit risk, settlement risk, liquidity risk, operational risk and legal risk. For example, there can be serious market disruptions if economic or political or other unforeseen events locally or overseas affect the market. Also, the settlement date of foreign exchange trades can vary due to time zone differences and bank holidays. When trading across foreign exchange markets, this may necessitate borrowing funds to settle foreign exchange trades. The interest rate on borrowed funds must be considered when computing the cost of trades across multiple markets. In addition to these types of risk there may be other factors such as accounting and tax treatment issues that Customers should consider.

¹Information regarding the performance of Interactive Brokers retail forex customers for the past 5 years is available upon request.

Day Trading Risk Disclosure Statement

This Day Trading Risk Disclosure Statement is being provided to you in the event your Interactive Brokers (IB) Reg T margin account becomes, or already is, classified as a Pattern Day Trader account. This does not apply to customers with Portfolio Margin accounts.

A Day Trade is defined as a buy and sell of the same security on the same day. Regulators define a Pattern Day Trader as any customer who executes four (4) or more Day Trades within five (5) business days. Pattern Day Traders that do not meet minimum equity requirements may be subject to regulatory restrictions.

For accounts that do not meet the $25,000 minimum equity, IB prevents the account from executing any additional day trades after three (3) day trades within a five (5) day period. The intention is to prevent customers that do not meet the equity minimum from being classified as Pattern Day Traders, which may subject the account to restrictions. Please review the IBKR website for additional details.

You should consider the following points before engaging in a day-trading strategy. For purposes of this notice, a "day-trading strategy" means an overall trading strategy characterized by the regular transmission by a customer of intra-day orders to effect both purchase and sale transactions in the same security or securities.

Day trading can be extremely risky. Day trading generally is not appropriate for someone of limited resources and limited investment or trading experience and low risk tolerance. You should be prepared to lose all of the funds that you use for day trading. In particular, you should not fund day-trading activities with retirement savings, student loans, second mortgages, emergency funds, funds set aside for purposes such as education or home ownership, or funds required to meet your living expenses. Further, certain evidence indicates that an investment of less than $50,000 will significantly impair the ability of a day trader to make a profit. Of course, an investment of $50,000 or more will in no way guarantee success.

Be cautious of claims of large profits from day trading. You should be wary of advertisements or other statements that emphasize the potential for large profits in day trading. Day trading can also lead to large and immediate financial losses.

Day trading requires knowledge of securities markets. Day trading requires in-depth knowledge of the securities markets and trading techniques and strategies. In attempting to profit through day trading, you must compete with professional, licensed traders employed by securities firms. You should have appropriate experience before engaging in day trading.

Day trading requires knowledge of a firm's operations. You should be familiar with a securities firm's business practices, including the operation of the firm's order execution systems and procedures. Under certain market conditions, you may find it difficult or impossible to liquidate a position quickly at a reasonable price. This can occur, for example, when the market for a stock suddenly drops, or if trading is halted due to recent news events or unusual trading activity. The more volatile a stock is, the greater the likelihood that problems may be encountered in executing a transaction. In addition to normal market risks, you may experience losses due to systems failures.

Day trading will generate substantial commissions, even if the per trade cost is low. Day trading involves aggressive trading, and generally you will pay commission on each trade. The total daily commissions that you pay on your trades will add to your losses or significantly reduce your earnings.

Day trading on margin or short selling may result in losses beyond your initial investment. When you day trade with funds borrowed from a firm or someone else, you can lose more than the funds you originally placed at risk. A decline in the value of the securities that are purchased may require you to provide additional funds to the firm to avoid the forced sale of those securities or other securities in your account. Short selling as part of your day-trading strategy also may lead to extraordinary losses, because you may have to purchase a stock at a very high price in order to cover a short position.

Potential Registration Requirements. Persons providing investment advice for others or managing securities accounts for others may need to register as either an "Investment Advisor" under the Investment Advisors Act of 1940 or as a "Broker" or "Dealer" under the Securities Exchange Act of 1934. Such activities may also trigger state registration requirements.

Interactive Brokers Order Routing and Payment for Order Flow Disclosure

1. IBKR's Order Routing System: IBKR provides brokerage clients two different account offerings: (1) IBKR-PRO; and (2) IBKR-LITE. Subject to certain restrictions, clients may choose between either offering depending on which they decide best satisfies their trading objectives and goals.¹ These offerings are designed to give IBKR clients the flexibility to prioritize the opportunity for zero-commission NMS stock trades and fixed-rate commission US equity option trades versus the amount and likelihood of price improvement they receive on trades. 
    
   IBKR-PRO orders are submitted to IBKR's high-speed Best Execution Order Routing System (SmartRouting^SM), which is designed to optimize execution price, speed and total cost of execution for stocks and options. IBKR constantly changes and enhances the SmartRouting system to adapt to changes in markets, new exchanges, new trading rules, etc. IBKR's SmartRouting system continually scans competing market centers and automatically seeks to route orders to the best market, taking into account factors such as quote size, quote price, exchange or ATS transaction fees or rebates and the potential availability of price improvement (execution at a better price than the National Best Bid or Offer ("NBBO"), "Price Improvement"). The IBKR SmartRouting system continually reevaluates market conditions and prices for pending IBKR client orders and dynamically re-routes orders as necessary. With IBKR-PRO, unless you direct your order to a specific market center or "algo" provider, IBKR's SmartRouting system retains control over the routing of your order for execution and does not deliver your order for another broker to route. 
    
   For some products, IBKR-PRO clients may directly route their orders to a particular market of their choice, although IBKR recommends that our clients use the IBKR SmartRouting system.
    
   IBKR also operates an Alternative Trading System (the IBKR ATS) in accordance with SEC Regulation ATS, on which it (i) executes IBKR client orders against each other or against one or more professional liquidity providers who send orders into the IBKR ATS and (ii) matches IBKR client option orders with professional liquidity provider interest (or other trading interest) for the purpose of initiating the various auction and Price Improvement mechanisms offered under U.S. option exchange rules. Order executions on the IBKR ATS are faster, eliminate exchange fees, and may offer Price Improvement. Statistical information regarding the quality of executions for orders effected through the IBKR ATS (e.g., average execution speed, percentage of orders receiving Price Improvement, etc.) is available on the IBKR website at: https://ibkr.com/regulatoryreports.
    
   IBKR-LITE clients are charged zero commission for NMS stock orders (except for certain order types, orders to execute at the open or close, orders executed outside of regular trading hours, and orders for stocks executed under $1.00²) and a fixed rate commission per contract for US equity options³. IBKR-LITE orders for NMS stocks are generally routed to select over-the-counter market-makers ("Market Makers") for handling. IBKR's agreements with the Market Makers provide Interactive Brokers payment for order flow from each Market Maker for trades executed with that Market Maker. A potential effect of these payments is reduced price improvement on executions received by IBKR-LITE clients, in proportion to the payment received by IBKR. 
    
   IBKR may also route IBKR-LITE orders to another broker, ATS, or exchange (each an "Away Route"), in which case IBKR may collect payment for order flow for trades executed at or through that Away Route; IBKR may also route IBKR-LITE orders in US equity options to Market Makers for handling, and may collect payment for order flow for options trades executed through such Market Makers and/or trades executed at an Away Route. By using the IBKR-LITE service, clients authorize IBKR to receive and retain such payments from Market Makers and Away Routes, in whole or in part, for IBKR's own account and not that of the client, in consideration for services provided by IBKR to the client. For more details, please see IBKR's quarterly order routing report at https://ibkr.com/regulatoryreports.
    
   In the event that IBKR is experiencing technical issues with its connections to all of its Market Makers at the time that an order in an NMS stock is to be routed for an IBKR-LITE client, IBKR may route the order using its SmartRouting functionality (as if the client had chosen the IBKR-PRO offering), but will still charge no commission on any resulting trades.
    
   IBKR may add other products to its IBKR-LITE-specific commission schedule offering from time to time.
    
   If an IBKR-LITE-specific commission schedule is not in place for a product, orders in such products are routed for IBKR-LITE clients in the same way as they are for IBKRPRO clients. For these products, the same commission structure will apply to both IBKR-LITE and IBKR-PRO. Where available, a "Fixed" commission model will apply to IBKR-LITE clients for such products. For more information, see below and at https://www.ibkr.com/en/index.php?f=1590. 
    
   If IBKR detects certain non-retail trading behaviors from an IBKR-LITE client, IBKR will route their non-marketable orders to lit exchanges rather than to market makers. 
2. Orders Sent Near the Opening of Trading: Please note that markets can be especially volatile near the opening of a trading session, with prices and available volume often changing rapidly and with data feeds from various markets potentially being slow or temporarily unavailable. IBKR cannot guarantee that orders sent at or near the opening of trading necessarily will receive the best posted price. You may want to consider the use of limit orders at the open, although market orders should be used if certainty of getting a fill is of greater concern to you than fill price. 
3. Order Conversion and Designation: IBKR may convert certain order types or apply conditions to certain IBKR client orders in order to facilitate an execution. For example, IBKR may simulate certain order types using order designations. Simulated order types may be used in cases where an exchange does not offer an order type or in cases where IBKR does not offer access to the "native" form of certain order types offered by an exchange. In addition, orders may be sent Immediate or Cancel, Fill-Or-Kill, All-Or-None, etc., in order to facilitate an immediate, automatic execution, consistent with the objectives of the client order. To protect client orders from significant and rapidly changing prices, IBKR may simulate market orders on exchanges by establishing a price ceiling for a buy order or a price floor for a sell order at a percentage beyond the inside bid/ask. While this cap or floor is set at a level intended to balance the objectives of execution certainty and minimized price risk, there exists a possibility that an execution will be delayed or may not take place. In addition, IBKR is required by exchanges and regulators to maintain "filters" in its systems that prevent executions at prices that might be deemed to be disruptive to an orderly market (or exchanges may have such filters in their systems). These filters may cause an otherwise marketable order not to be executed or to be delayed in execution, even if the client might want the order to be executed immediately at a certain price. In accordance with our regulatory obligations as a broker, IBKR may also reject orders exceeding certain size thresholds, based upon factors including the normal volume in the product, the type of order, the marketability of the order, and other factors which may affect the likelihood that the order could result in market disruption.
4. Important Characteristics and Risks of Using Stop Orders: A Stop Order - i.e., a Stop (Market) Order - is an instruction to buy or sell at the market price once your trigger ("stop") price is reached. Please note that a Stop Order is not guaranteed a specific execution price and may execute significantly away from its stop price, especially in volatile and/or illiquid markets. Stop Orders may be triggered by a sharp move in price that might be temporary. If your Stop Order is triggered under these circumstances, you may buy or sell at an undesirable price. Sell Stop Orders may make price declines worse during times of extreme volatility. If triggered during a sharp price decline, a Sell Stop Order also is more likely to result in an execution well below the stop price. Placing a limit price on a Stop Order may help manage some of these risks. A Stop Order with a limit price - a Stop (Limit) Order - becomes a limit order when the instrument reaches the stop price. By using a Stop (Limit) Order instead of a regular Stop Order, you will receive more certainty regarding the execution price, but there is the possibility that your order will not be executed at all if your limit price is not available in the market when the order is triggered. 
5. Important Characteristics and Risks of Using Market Orders: Please note that a Market Order is an instruction to execute your order at any price available in the market. A Market Order is not guaranteed a specific execution price and may execute at an undesirable price. If you would like greater control over the execution prices you receive, please submit your order using a Limit Order, which is an instruction to execute your order at or better than the specified limit price. 
6. Potential Effects of High Volumes and Market Volatility: High volumes of trading and price volatility may lead to wider market volatility and extreme market conditions. It is important that IBKR clients understand the potential risks this presents, including: 
   1. Delay and Price Issues: High volumes of trading, either around the market open, market close or other times of day, may cause delays in execution (or associated reporting) and/or executions at prices significantly different than the market price quoted or displayed at the time of order entry. 
   2. Changes to Order Handling and Restrictions on Order Acceptance: Volatile or extreme market conditions may necessitate changes to IBKR's order handling procedures, margin requirements, and/or restrictions on the types of orders IBKR will accept. IBKR is not required to receive or accept orders from clients, particularly in circumstances where IBKR believes that the associated compliance, legal, financial, credit or other risks are not acceptable. IBKR may determine that it is necessary to change order handling procedures or margin requirements, or restrict or prohibit trading, to limit IBKR's and/or clients' exposure to extraordinary market, financial or other risks. IBKR may make these changes in its sole discretion, without notice. For example, IBKR may determine that it is necessary to restrict certain transactions to closing-only status (meaning that clients may close existing positions but may not open new positions), make certain products non-shortable (meaning that clients may not open short positions in a particular product), or increase margin requirements. 
7. Payment for Order Flow, Dark Pools, Liquidity Provider and Affiliate Relationships: 
   1. IBKR-LITE Orders
      1. IBKR-LITE Orders in NMS Stocks and US Equity Options: Please see paragraph 1 for a discussion of IBKR's policies regarding payment for order flow in connection with IBKR-LITE orders in NMS stocks and US equity options. 
      2. Specific Provisions Regarding IBKR-LITE Orders in US Equity Options: 
         1. IBKR may route orders in US equity options to Market Makers. For US equity options orders not routed to Market makers, IBKR employs its SmartRouting system to try to achieve the best execution for client option orders. The SmartRouting system is designed to achieve an execution price at or better than the NBBO by utilizing relationships with liquidity providers, who may provide Price Improvement through the various auction and Price Improvement mechanisms offered under U.S. option exchange rules. These relationships benefit IBKR clients, who may receive Price Improvement for their options orders. IBKR may receive payment in the form of commissions or other payments from the liquidity providers for these executions.
         2. Several options exchanges impose "maker-taker" fees and rebates, in which exchange members are charged for orders that take liquidity (i.e., marketable orders that trade against a posted quote or limit order) and receive a rebate for orders that add liquidity to the exchange (i.e., non- marketable limit orders that are posted and then trade against incoming marketable orders), or vice versa. By electing IBKR-LITE, you are agreeing to allow IBKR to retain any rebates it receives from an exchange in connection with your order being routed at that exchange. 
         3. Under certain circumstances, IBKR may route a marketable option order to an exchange that is not currently posting the NBBO but which may be willing to execute the order at the NBBO. Generally, IBKR will do this in order to avoid or reduce the fee for executing the order, compared to routing to a different exchange. In addition, in the limited circumstances where IBKR routes orders in this manner, IBKR generally guarantees a fill at the NBBO at the time the order was routed.
         4. Option exchange payment for order flow programs may result in payments to specialists or primary market makers, some portion of which may be paid to IBKR. 
      3. Other Products: For products not subject to an IBKR-LITE specific commission schedule, entitled to zero-commission trading under IBKR-LITE, the same commission structure will apply to both IBKR-LITE and IBKR-PRO. Where available, a "FIXED" commission model will apply to IBKR-LITE clients for such products. For more information, see below and at https://www.ibkr.com/en/index.php?f=1590.  
   2. IBKR-PRO Orders
      1. Dark Pool and ATS Executions for Clients' Marketable Stock and ETF Orders: IBKR maintains connections to "dark pool" ATSs ("Routeaway Dark Pools") that may execute IBKR-PRO client marketable orders in NMS stocks. IBKR clients benefit from IBKR's access to dark pools. Dark pools provide a source of substantial additional liquidity. Dark pools generally charge no execution fees or lower execution fees than exchanges. Dark pools also provide fast executions and the possibility of executions at prices more favorable than the prevailing NBBO.
          
         IBKR receives rebate payments for routing and executing marketable client orders for Regulation NMS stocks at some Routeaway Dark Pools. As of May 29, 2018, IBKR generally passes the amount (or approximate amount) of any such rebate to (i) Tiered-commission IBKR-PRO clients as a venue rebate; and to (ii) Fixed-commission IBKR-PRO clients in the form of a reduction to the standard U.S. stock commission.  
      2. Liquidity Provider Relationships in the IBKR ATS and Executions of Client Orders Against Those Liquidity Providers in the IBKR ATS: IBKR has entered arrangements with certain institutions under which such institutions may send liquidity-adding orders in NMS stocks to the IBKR ATS. These orders are held within the IBKR ATS and are not displayed in the national market. If an IBKR-PRO client marketable order could be immediately executed against such an order held in the IBKR ATS (at the NBBO or at a better price than the NBBO), the orders may be crossed and the execution reported to the National Market System. This arrangement provides extra potential liquidity (size) for IBKR-PRO client orders and may provide faster executions (since the orders do not have to be routed out to an exchange), as well as providing the possibility of Price Improvement (since the orders may be executed at a better price than available on an exchange). 
          
         IBKR may receive payment in the form of commissions or commission equivalents from the liquidity providers for these executions in the IBKR ATS. In the event IBKR receives any such payment, IBKR generally passes the amount (or approximate amount) of the benefit to the client as follows, to (i) Tiered-commission IBKR-PRO clients as a venue rebate; and to (ii) Fixed-commission IBKR-PRO clients in the form of a reduction to the standard U.S. stock commission. 
      3. Client-to-Client Order Crosses in the IBKR ATS: For client orders in Regulation NMS stocks that result in client-to-client crosses on the IBKR ATS, IBKR charges and/or provides the following commissions, fees, and/or rebates:
         1. Non-Marketable Orders Directed to and Executed in the IBKR ATS: IBKR does not pay rebates or commission breaks to clients for non-marketable orders directed to and executed in the IBKR ATS ("Directed IBKR ATS Order(s)"). 
         2. Orders Smart-Routed to and Executed in the IBKR ATS Against Directed IBKR ATS Orders:If IBKR smart-routes an order to the IBKR ATS and that order is executed against a Directed IBKR ATS Order, IBKR will provide: 
            • A fixed per-share rebate to the IBKR-PRO Tiered-commission client who submitted the smart-routed order; or 
            • A fixed per-share commission reduction to the IBKR-PRO Fixed-commission client who submitted the smart-routed order.
         3. Non-Marketable Orders Smart-Routed to the IBKR ATS Which Were Also Eligible for Execution at an Exchange: IBKR may smart-route a non-marketable order to an exchange and later re-route that order to the IBKR ATS (the "Eligible Resting Non-Marketable Order") where it executes against another client order. In this instance: 
            • An IBKR-PRO Tiered-commission client that submitted the Eligible Resting Non-Marketable Order will receive the add-liquidity rebate (or pay the add-liquidity fee, if applicable) that the client would have received (or paid) if their resting order had executed at the exchange on which it had been resting. 
            • An IBKR-PRO Fixed-commission client that submitted the Eligible Resting Non-Marketable Order will pay the typical fixed commission.
         4. Orders Smart-Routed to the IBKR ATS Which Are Executed Against Eligible Resting Non-Marketable Order(s): IBKR may smart-route a client order to the IBKR ATS so that it executes against an Eligible Resting Non-Marketable Order. In this instance: 
            • An IBKR-PRO Tiered-commission client that submitted the order will be charged the venue take-fee (or receive the venue take-rebate, if applicable) that the client would have paid at the exchange to which the client's order would otherwise have been routed. 
            • An IBKR-PRO Fixed-commission client that submitted the order will pay the standard fixed commission. 
      4. IBKR-PRO Tiered Commission Structure for Orders Routed to Exchanges: Under IBKR's Tiered commission model, IBKR passes to Tiered commission clients some or all of certain rebate payments IBKR receives for executing stock orders at exchanges, although the Tiered commission model is not intended to be a direct pass-through of exchange and third-party fees and rebates. For example, IBKR may receive enhanced rebate payments for exceeding volume thresholds on particular markets, but typically will not directly pass these enhancements to clients. Likewise, IBKR does not pass to clients all of the rebates IBKR may receive for orders in pink sheet or OTCBB stocks. In certain circumstances, IBKR may receive discounts with respect to third party fees, including exchange and/or clearing fees, that may not pass through to clients. 
      5. Options: IBKR does not deliver its IBKR-PRO option orders to another broker to handle and route. Rather, IBKR employs its SmartRouting system to try to achieve the best execution for client option orders. The SmartRouting system is designed to achieve an execution price at or better than the NBBO by utilizing relationships with liquidity providers, who may provide Price Improvement, including by matching client interest in the IBKR ATS in order to initiate auction and Price Improvement mechanisms offered under U.S. option exchange rules. These relationships benefit IBKR clients, who may receive Price Improvement for their options orders. IBKR may receive payment in the form of commissions or other payments from the liquidity providers for these executions. 
          
         Several options exchanges impose "maker-taker" fees and rebates, in which exchange members are charged for orders that take liquidity (i.e., marketable orders that trade against a posted quote or limit order) and receive a rebate for orders that add liquidity to the exchange (i.e., non- marketable limit orders that are posted and then trade against incoming marketable orders), or vice versa. The charges imposed or rebates offered by these exchanges affect the total cost of execution, and IBKR's SmartRouting System takes this into account in determining where to route option orders - trying to minimize the costs that clients incur. If multiple exchanges are quoting at the NBBO for an option order and IBKR has discretion as to where to send the order or a portion of it, IBKR generally will "break the tie" by sending the order to an exchange where it will receive the most payment for the order. 
          
         Under certain circumstances, IBKR may route a marketable option order to an exchange that is not currently posting the NBBO but which may be willing to execute the order at the NBBO. Generally, IBKR will do this in order to avoid or reduce the fee for executing the order, compared to routing to a different exchange. IBKR generally will share the economic benefit of routing orders in this manner with clients in the form of reduced execution fees, although IBKR does not guarantee that it will share such benefit. In addition, in the limited circumstances where IBKR routes orders in this manner, IBKR generally guarantees a fill at the NBBO at the time the order was routed. 
          
         Under IBKR's Tiered commission model, IBKR passes to Tiered-commission clients some or all of certain rebate payments IBKR receives for executing option orders, although the Tiered-commission model is not intended to be a direct pass-through of exchange and third-party fees and rebates.⁴ For example, IBKR may receive enhanced rebate payments for exceeding volume thresholds on particular markets, but typically will not directly pass these enhancements to clients. Likewise, IBKR does not pass to clients all of the rebates IBKR may receive for liquidity taking orders, complex orders or orders executed in price improvement auctions. Traditional exchange payment for order flow programs result in payments to specialists or primary market makers, some portion of which may be paid on to IBKR. IBKR does not pass these payments directly to clients. Notwithstanding anything else to the contrary herein, certain public customer complex option orders executed on certain exchanges may be subject to take liquidity charges without regard to the manner of execution and corresponding exchange fee/rebate that may be received by IBKR.  For example, such a circumstance may arise where the exchange is not able to confirm whether an order qualifies for add liquidity or take liquidity treatment at the time of execution. 
8. Internalization of Customer Order Flow: IBKR may internalize non-directed whole share customer order flow through an affiliate. The internalization of customer orders is intended to provide the opportunity for improved execution quality (i.e., increased price improvement) and/or reduced execution costs without reducing execution quality. The internalization of a customer order may enable the affiliate of IBKR to generate a trading profit by trading as principal. Customers have the option to opt out of internalization of the whole-share portions of their stock orders; customers cannot opt out of internalization for the fractional-share portion of any order they submit.
9. Affiliate Investments in Exchanges: An affiliate or affiliates of Interactive Brokers LLC own(s) minority interests in OneChicago (security futures exchange) and a substantial, minority investment in the Boston Options Exchange Group LLC, which operates the BOX Options Exchange. 
10. Quarterly Order Routing Reports and Other Order Routing Information Available upon Request: U.S. Securities and Exchange Commission rules require all brokerage firms to make publicly available quarterly reports describing their order routing practices. IBKR's quarterly order routing reports are available on the IBKR website at https://ibkr.com/regulatoryreports, or you can contact IBKR Client Services.  
     
    In addition to the basic quarterly reports, under Rule 606 of SEC Regulation NMS, a broker-dealer is required upon a client request to provide information regarding the identity of the market center to which the client's orders were routed in the six months prior to the request; whether the order was a directed or non-directed order, and the time of the transaction, if any, that resulted from such order. Please contact the IBKR Client Services Desk in writing through the information on the IBKR website at ibkr.com/ (https://www.ibkr.com/help) if you wish to receive the foregoing routing information for any order(s) within the past six months. Please type "Request for Order Routing Information" in the subject line of your request and please include your name, user id and account number as well as the date of the order, the security, the quantity, and any other information necessary to identify the order (e.g., the time of day if there were several similar orders that day.) 
     
    As long as consistent with applicable securities laws and regulations, we may share anonymized account information or anonymized delayed order information with third parties (and/or share such information among our affiliates) for the purpose of analysis, research, market data compilation, product creation, establishing order routing and execution relationships, or for any other lawful purpose. 

OCC Risk Disclosure Statement and Acknowledgements

OCC Risk Disclosure

I acknowledge that:

1. I have received and carefully read each section of, and the supplements to, the Options Clearing Corporation ("OCC") document "Characteristics and Risks of Standardized Options" (the "OCC Risk Disclosure Document") ;
2. I have received and carefully read the "Special Statement for Uncovered Option Writers" (set forth below);
3. I have received and carefully read the "Disclosure Regarding Interactive Brokers' Procedures for Allocating Equity Option Exercise Notices Assigned by OCC" ("IB Exercise Allocation Disclosure" ); (Requires Adobe Reader. Download Reader.)
4. I understand the OCC Risk Disclosure Document, the "Special Statement for Uncovered Option Writers" and the IB Exercise Allocation Disclosure, each of which is in a language I fully understand; and
5. If there is any aspect of the OCC Risk Disclosure Document, the "Special Statement for Uncovered Option Writers" or the IB Exercise Allocation Disclosure that I do not understand, I shall consult my independent adviser and obtain a full understanding of such term(s).

Special Statement for Uncovered Option Writers

Uncovered option writing is permitted for customers with Options Level 3 and Options Level 4 trading permissions. There are special risks associated with uncovered option writing which expose the investor to potentially significant loss. Therefore, this type of strategy may not be appropriate for all customers approved for options transactions.

1. The potential loss of uncovered call writing is unlimited. The writer of an uncovered call is in an extremely risky position, and may incur large losses if the value of the underlying instrument increases above the exercise price.
2. As with writing uncovered calls, the risk of writing uncovered put options is substantial. The writer of an uncovered put option bears a risk of loss if the value of the underlying instrument declines below the exercise price. Such loss could be substantial if there is a significant decline in the value of the underlying instrument.
3. Uncovered option writing is thus suitable only for the knowledgeable investor who understands the risks, has the financial capacity and willingness to incur potentially substantial losses, and has sufficient liquid assets to meet applicable margin requirements. In this regard, if the value of the underlying instrument moves against an uncovered writer's options position, the investor's broker may request significant additional margin payments. If an investor does not make such margin payments, the broker may liquidate stock or options positions in the investor's account, with little or no prior notice in accordance with the investor's margin agreement.
4. For combination writing, where the investor writes both a put and a call on the same underlying instrument, the potential risk is unlimited.
5. If a secondary market in options were to become unavailable, investors could not engage in closing transactions, and an option writer would remain obligated until expiration or assignment.
6. The writer of an American-style option is subject to being assigned an exercise at any time after he has written the option until the option expires. By contrast, the writer of a European-style option is subject to exercise assignment only during the exercise period.

NOTE: It is expected that you will read the booklet entitled CHARACTERISTICS AND RISKS OF STANDARDIZED OPTIONS available from your broker. In particular your attention is directed to the chapter entitled Risks of Buying and Writing Options. This statement is not intended to enumerate all of the risks entailed in writing uncovered options.

Risks of Trading Equity Options and Terms and Conditions for Trading Equity Options

Customers trading equity options understand and agree to the following:

1. Customer understands that trading equity options is highly speculative in nature and involves a high degree of risk.
2. Customer acknowledges that Customer has read and fully understands (a) the current Options Clearing Corporation ("OCC") disclosure document "Characteristics and Risks of Standardized Options" (the "OCC Document") and (b) the "Special Statement for Uncovered Option Writers." Customer agrees to seek clarification of any term, condition or risk contained in either of these documents prior to making such acknowledgment to IB.
3. Customer is financially able to undertake the risks associated with trading equity options and withstand any losses incurred in connection with such trading (including the total loss of premiums paid by Customer for long put and call options, margin requirements for short put and call options, and transaction costs).
4. Among the risks Customer acknowledges are: (a) option contracts are traded for a specified period of time and have no value after expiration; (b) trading halts in the underlying security, or other trading conditions (for example, volatility, liquidity, systems failures) may cause the trading market for an option (or all options) to be unavailable, in which case, the holder or writer of an option would not be able to engage in a closing transaction and an option writer would remain obligated until expiration or assignment.
5. The IB System is an electronic system and is, therefore, subject to unavailability. Customer represents that it has alternate trading arrangements for the placement of Customer's orders and shall use such arrangements in the event that the IB System becomes unavailable. Although the IB System is designed to perform certain automatic functions, IB does not warrant that the IB System will perform as it is designed to, and IB will not have any liability to Customer for losses or damages which result from such failures of performance or unavailability. Subject to the foregoing, Customer acknowledges that the IB System is designed to automatically liquidate Customer positions if Customer's account equity is not sufficient to meet margin requirements.
6. Customer has reviewed and understands the applicable margin requirements for trading equity options.
7. Each equity option transaction entered into is subject to the rules and regulations of the Securities & Exchange Commission ("SEC"), the Financial Industry Regulatory Authority ("FINRA"), the OCC, the self-regulatory organizations that regulate IB and, the relevant options exchanges. Customer is aware of and agrees to be bound by the rules applicable to the trading of options contracts promulgated by the SEC, FINRA, the OCC and the self-regulatory organizations that regulate IB and the relevant options exchanges.
8. Equity options traded in the US are issued by the OCC.
9. Customer is aware of and agrees not to, alone or in concert with others, exceed the position and exercise limits imposed by FINRA or by other exchange rules and regulations, including but not limited to FINRA Rules 2360(b)(3) and (4).
10. With certain exceptions, IB will not execute a Customer order to purchase an equity option if Customer does not have equity in its account at least equal to the full purchase price of a put or call option (equity options may not be purchased on margin).
11. Customer shall comply with IB margin requirements in connection with Customer's sale of put and call options.

12. Customers who wish to exercise an option on a particular trading day acknowledge that they must provide specific, written instructions to IB using the procedure specified on the IB website before the Close Out Deadline specified. Customer further acknowledges that, absent receipt of such instructions, IB has no obligation to exercise Customer's option on any given trading day or prior to the expiration of the option. Customer acknowledges that, subject to paragraph H below, OCC will automatically exercise any long equity option held by a Customer that is in-the-money by $.01 or more at expiration, absent specific instructions to the contrary provided by Customer to IB using the procedures specified on the IB website.

    In certain circumstances, including if there is a trading halt in the security underlying the option, or a corporate action has occurred on an underlying resulting in uncertain pricing on a deliverable, OCC may suspend its automatic exercise-at-expiration processing. OCC issues memos notifying holders of the suspension of automatic exercise and the need for holders to affirmatively exercise their options. IB monitors these memos and notifies holders of the need to affirmatively exercise their options. But IB undertakes these actions on a reasonable efforts basis only. Accordingly, if you are holding long options that you expect to expire in-the-money, you are responsible for checking the OCC website to determine whether automatic exercise-on-expiry has been suspended or you may lose the value of your options if they expire and are not automatically exercised. To confirm whether OCC has suspended its automatic exercise-at-expiration functionality on a particular underlying, customers should review the memos on the OCC website at https://infomemo.theocc.com/infomemo/search.

13. Customer understands that OCC assigns exercises to clearing firms such as IB and Customer acknowledges that it has read and understands the description of the OCC assignment procedures available on request from the OCC as set forth in Chapter VIII of the OCC Document. Customer acknowledges that, upon assignment, Customer shall be required: (1) in the case of an equity option, to deliver or accept the required number of shares of the underlying security, or (2) in the case of an equity index option, to pay or receive the settlement price, in cash. Customer understands that it may not receive notice of an assignment from IB until one or more days following the date of the initial assignment by OCC to IB and that the lack of such notice creates a special risk for uncovered writers of physical delivery call stock options. Customer acknowledges that it has read and understands this risk as described in Chapters VIII and X of the OCC Document.
14. Customer is responsible for entering an offsetting transaction to close out a Customer position, or to exercise an equity option by written e-mail instruction to IB prior to the expiration date, and Customer's failure to do so may result in the equity option expiring worthless, regardless of the monetary value of the equity option on its expiration date.
15. If, prior to expiration of an option contract, Customer does not have sufficient equity to meet the initial margin requirement for the purchase or sale of the underlying security (the higher of IB's "house" margin requirements or margin requirements mandated by exchanges or regulators), then IB shall have the option, at its discretion, to: (1) decline to purchase or sell such underlying security for the customer's behalf (e.g., by filing a Contrary Exercise Notice): OR (2) exercise the option and liquidate the underlying security position which results from the exercise of the option contract. If Customer violates the IB Customer Agreement by failing to close out an open option position prior to expiration, which creates a margin deficiency (e.g., upon exercise or automatic exercise of the option), then Customer shall be liable for resulting losses and costs and shall not be entitled to any profits or gains.
16. In connection with the exercise of a long put option that results in a short position in the underlying stock, Customer acknowledges that: (1) short sales may only be effected in a margin account and are subject to initial and maintenance margin requirements; and (2) if IB is unable to borrow such stock on Customer's behalf or if a lender subsequently issues a recall notice for such stock, then IB, without notice to Customer, is authorized by Customer to cover Customer's short position by purchasing stock on the open market at the then current market price and Customer agrees that it shall be liable for any resulting losses and all associated costs incurred by IB. As noted above, the market value of short stock is treated as a debit item to Customer's IB margin account.

Stock Stop Order Disclosure

Interactive Brokers ("IBKR") is furnishing this document to you to provide information about the manner in which stop and stop-limit orders that you submit to IBKR to buy or sell stocks and warrants will be managed.

A stop order is an order to buy or sell a stock once the price of the stock reaches a specified price, known as the stop price. When the stop price is reached, a stop order becomes a market order. A buy stop order is entered at a stop price above the current market price. A sell stop order is entered at a stop price below the current market price. Investors generally use a sell stop order to limit a loss or to protect a profit on a stock that they own.

A stop-limit order is an order to buy or sell a stock that combines the features of a stop order and a limit order. Once the stop price is reached, a stop-limit order becomes a limit order that will be executed at a specified price (or better).

IBKR offers its customers several ways to submit stop and stop-limit orders in stocks and warrants. On most exchanges, IBKR implements and manages stop (or stop-limit) orders in the firm's systems, submitting market (or limit) orders to the exchange when the customer-specified trigger price has been reached and passed. On some exchanges, IBKR may submit stop and/or stop- limit orders using the exchange's native order type. For each exchange on which a customer may trade, IBKR specifies on the IBKR website whether stop and stop-limit orders are managed (i.e., "simulated") by IBKR or submitted using the exchange's native order type. (This information is available under "Order Type" on the page on the IBKR website concerning each exchange.)

For stop and stop-limit orders that IBKR simulates, the order will be triggered and a market (or limit) order will be submitted for execution when the following occurs (unless the customer specifies otherwise when submitting the order):

1. The primary exchange on which the stock trades is open, is holding regular trading hours, and has a valid bid/ask quote for the stock. Regular trading hours are usually between 9:30a.m. - 4:00p.m. Eastern Time, Monday through Friday for U.S. exchange-listed stocks. (Please note that OTCBB- and Pink- listed securities are not subject to these limitations.); and
2. The last sale price for the specific stock is at or above (for buy stop orders) or at or below (for sell stop orders) the customer's specified trigger price; and
3. The last trade price is within, or not more than 0.5% outside of, the consolidated bid/ask for the stock.

These additional requirements are subject to change, including the leeway percentage of 0.5% outside of the consolidated bid/ask for the stock. Please check the IBKR website for the most current information.

IBKR also allows customers to customize the manner in which their stop and stop-limit orders are triggered. Customers may change the trigger method to include or exclude certain trigger criteria (e.g., last price, bid/ask, midpoint of bid/ask, regular trading hours only, etc.) based on the customer's specific trading objectives. Information on how to customize the trigger methodology for stop and stop-limit orders is provided on the IBKR website and in the IB Trader Workstation User's Guide.

Important notes concerning stop and stop-limit orders:

1. Native Stop or Stop-Limit Order Types Offered by Exchanges May Differ from the Traditional Order Type. Stop and stop-limit orders submitted using an exchange's native order type may have additional non-standard attributes or be managed in a way different than the traditional definition of a stop or stop-limit order. Please review the exchange's own website and/or contact the exchange for more information about how an exchange may handle a stop or stop-limit order submitted using the exchange's native order type. Among other things, exchanges may include attributes in native stop orders that result in the order not executing at all.
2. There is No Guarantee That a Stop or Stop-Limit Order Will Be Executed At or Near the Trigger Price or Will Be Executed At All. Please be aware that a stop or stop-limit order may not be triggered or be executed at or near the specified trigger price. Among other things, execution venues may fail to honor their posted prices or may experience delays or failures that may prevent or delay a stop order from being executed. In addition, market events may result in a stop order executing far from the customer's specified trigger price. For instance, in situations where many customers submit a stop order with a similar trigger point or there is a lack of liquidity in the market, a stop order may execute a significant amount away from the specified trigger price and a stop-limit order may not execute at all.

DISCLOSURE REGARDING INTERACTIVE BROKERS' PROCEDURES FOR ALLOCATING EQUITY OPTION ASSIGNMENT NOTICES FROM OCC

As described in the Options Clearing Corporation ("OCC") Publication "Characteristics and Risks of Standardized Options", the OCC assigns exercise notices to clearing firms such as Interactive Brokers LLC ("IB LLC"), [the US-located affiliate of Interactive Brokers (U.K.) Limited ("IB UK"), Interactive Brokers Australia Pty Limited ("IBAU"), Interactive Brokers Canada, Inc. ("IBC"), Interactive Brokers Central Europe Zrt. ("IBCE"), Interactive Brokers Hong Kong Limited ("IBHK"), Interactive Brokers Ireland Limited ("IBIE"), and Interactive Brokers Singapore Pte. Ltd. ("IBSG") that arranges for the execution and clearing of IB UK, IBAU, IBC, IBCE, IBHK, IBIE, and IBSG customer trades] using a specified assignment procedure. IB LLC, in turn, is required to maintain a procedure to allocate such exercise notices to those customer accounts carried by IB LLC that hold short positions in the relevant options. Upon assignment, customers whose accounts are carried by IB LLC shall be required: (1) in the case of an equity option, to deliver or accept the required number of shares of the underlying security, or (2) in the case of an equity index option, to pay or receive the settlement price, in cash. Customer understands that it may not receive notice of an assignment until one or more days following the date of the initial assignment by OCC to IB LLC and that the lack of such notice creates a special risk for uncovered writers of physical delivery call stock options.

Described below are IB LLC's procedures for allocation of exercise notices, which are based on a random selection process:

Steps

1. Each night, IB LLC receives the "OCC E&A" (exercise and assignment activity) file from the OCC in machine-readable format setting forth, on a per contract basis, the aggregate exercise and assignment quantities to IB LLC.
2. For each contract assignment record, the IB LLC System compiles a list, in ascending account number order, of all customer accounts held at IB LLC with short positions in the relevant contract.
3. If only one customer holds a short position in the contract assigned, that customer is automatically allocated the assignment and no lottery is needed.
4. If more than one customer holds a short position in the contract assigned, the IB LLC System runs an automated random lottery to determine the allocation of quantities that are to be assigned to each customer. The IB LLC System shall:
   1. Assign two sequence ranges to each customer's holdings (see Exhibit A).
   2. Generate a random number to find a "Starting Point". The Starting Point is the customer contract sequence number from which the allocation of the assignment quantity begins. To generate a Random Number, the IB System will:
      • Initialize the Oracle random number generator with the system time (HH24MISS)
      • Find the Random Number by taking the MOD (random number,total position) + 1 to ensure that the Random Number is between one and the total number of short contracts.

   (Note: the IB System will generate a new Random Number for each lottery to be run.)

5. The IB LLC System will then (a) find the account that has the assigned sequence range into which the Random Number falls; and (b) select contracts to be assigned in increments of one, beginning with the contract that correlates with the Random Number until the total number of contracts assigned has been satisfied.
6. The IB LLC System will then process the assigned positions by (a) removing the options positions from customers' accounts and (b) if the option delivers underlying stock, entering the corresponding stock trades at the strike price or (c) if the option assignment settles in cash, entering the corresponding cash debit.

EXHIBIT "A"

Assume there are 1186 options contracts held at OCC for 10 customers and that 50 contracts are assigned to IB LLC by OCC.

1. Assign sequence numbers to each security:
   

   		Assigned Sequence Numbers
   Customer Accounts	No. of Contracts held at OCC	1st Range	1st Range
   A	1	0001	1187
   B	50	0002-0051	1188-1237
   C	100	0052-0151	1238-1337
   D	2	0152-0153	1338-1339
   E	1	0154	1340
   F	1	0155	1341
   G	1000	0156-1155	1342-2341
   H	1	1156	2342
   I	10	1157-1166	2343-2352
   J	20	1167-1186	2353-2372
   Total in OCC	1186

2. FIND A STARTING RANDOM NUMBER BETWEEN 0001 AND 1186 using the Oracle random number generator.
3. ASSUMING THE RANDOM NUMBER GENERATED WAS 0396, ALLOCATE THE 50 CONTRACTS TO CUSTOMERS STARTING AT CONTRACT NUMBER 0396.

SUMMARY OF ALLOCATION
Customer Accounts	No. of Contracts held at OCC	Allocation of Assigned Options Contracts
A	1	0
B	50	0
C	100	0
D	2	0
E	1	0
F	1	0
G	1000	50
H	1	0
I	10	0
J	20	0
Total in OCC	1186	50

Required Disclosures and Supplemental Agreement for Security Futures Trading at Interactive Brokers

1. Introduction
   This information is being provided to you by Interactive Brokers ("IB") to ensure that you understand the risks inherent in trading security futures and also so that you understand how your security futures account is being handled by IB. You must review this document carefully and sign it at the bottom in order to be approved to trade security futures products through IB.

   You should be aware that security futures are highly leveraged investments and the risk of loss in trading these products can be substantial. Security futures are not suitable for all investors and you must carefully review this document and consult with a financial advisor, if necessary, to determine whether to trade security futures. IB does not provide any investment advice or recommendations, and you will be solely responsible for decisions regarding the security futures trading conducted in your account.

2. Nature of Your Security Futures Account
   Under the federal regulations that apply to security futures, security futures positions may be held in a securities trading account subject to Securities and Exchange Commission (SEC) regulations or in a commodities trading account subject to Commodity Futures Trading Commission (CFTC) regulations.

   Because IB is fully registered with both the SEC and the CFTC, IB offers both securities accounts and commodities accounts. Most securities futures products are held in an IB securities account and are subject to SEC customer protection rules. However, certain securities futures products are held in a commodities account and are therefore subject to CFTC customer protection rules. Additional information regarding whether a particular securities future product is held in a securities or commodities account may be found on IB's website.

   The types of protections offered to investors for securities and commodities accounts are different. The different protections available to securities accounts and commodities accounts are described in Section 6 of the FINRA/NFA Standardized Risk Disclosure for Security Futures Contracts, discussed below.

3. Standardized Risk Disclosure for Security Futures Contracts
   The National Futures Association (NFA) and the Financial Industry Regulatory Authority (FINRA) have jointly prepared a Standardized Risk Disclosure for Security Futures Contracts. It contains valuable information regarding trading of security futures contracts and you should review it carefully before investing in security futures.

   To review the FINRA/NFA Standardized Risk Disclosure for Security Futures Contracts, click here.

   NOTE: Viewing the Standardized Risk Disclosure requires Adobe Acrobat. To download Adobe Acrobat, click here. If you wish to receive a hard copy of the disclosure, call IB Customer Service at (877) 442-2757.

4. Supplemental Agreement for Security Futures Trading
   The Supplemental Agreement provisions below relate to security futures trading in Customer' s IB account and are in addition to the terms and conditions of the IB Customer Agreement, and the Customer Agreement is incorporated herein by reference.

   By signing below, Customer acknowledges and agrees to the following:

1. Customer acknowledges that Customer's securities futures positions may be held in either a securities or commodities account, in IB's sole discretion. Customer acknowledges that securities futures held in an IB securities account will receive the regulatory protections of a securities account. Customer acknowledges that securities futures held in an IB commodities account will receive the regulatory protections of a commodities account.
2. Customer acknowledges that IB may in the future, at its sole discretion, decide to hold customer security futures positions in IB securities accounts or commodities accounts and may not allow customers to make this choice. If IB determines to do this, it will provide required notice to customers of the change.
3. Customer represents that Customer has received and reviewed the FINRA/NFA Standardized Risk Disclosure for Security Futures Contracts.
4. Customer acknowledges that security futures are highly leveraged investments that are not suitable for all investors. Customer acknowledges that IB representatives are not authorized to provide investment, trading or tax advice and therefore will not provide advice or guidance on trading or hedging strategies involving security futures. Customers who need advice or guidance regarding security futures trading or investments should consult a financial advisor.
5. Customer acknowledges that Customer must review and be aware of, and that Customer is bound by, the rules applicable to the trading of security futures, as established by FINRA, the NFA and the security futures exchanges. Customer represents that it is aware of and agrees not to violate any applicable position limits regarding security futures.

Risk Disclosure Statement for Trading Bonds

Interactive Brokers ("IBKR") is furnishing this disclosure to clients to provide additional information regarding the characteristics and risks associated with fixed income securities ("bonds").

BEFORE TRADING BONDS YOU SHOULD CONSIDER CONSULTING A FINANCIAL ADVISOR, WHO CAN PROVIDE ADVICE ON WHETHER PARTICULAR INVESTMENTS SUIT YOUR FINANCIAL GOALS.

IBKR PROVIDES EXECUTION AND CLEARING SERVICES AND DOES NOT PROVIDE SPECIFIC TRADING OR INVESTMENT ADVICE OR RECOMMENDATIONS. IBKR DOES NOT MONITOR CLIENT ACCOUNTS, TRADES, OR INVESTMENT DECISIONS TO DETERMINE IF THEY ARE APPROPRIATE OR SUITABLE FOR THE CLIENT'S FINANCIAL NEEDS.

BEFORE TRADING ANY PARTICULAR BOND, YOU SHOULD UNDERSTAND THE TERMS AND CONDITIONS OF THE BOND, INCLUDING ITS CREDIT RATING, ITS MATURITY, ITS RATE AND YIELD, WHETHER IT IS CALLABLE, AND OTHER RELEVANT INFORMATION.

More information on bond trading can be found on FINRA'S website at:
https://www.finra.org/investors/learn-to-invest/types-investments/bonds.

1. Characteristics of Bonds

What is a bond?
A bond is a loan an investor makes to a corporation, government, federal agency or other organization in exchange for interest payments over a specified term plus repayment of principal at the bond's maturity date.

What are the types of bonds
Some of the bonds commonly traded on IBKR systems include:

1. U.S. Government Bonds

Bonds issued by the U.S. government are called Treasuries. These are grouped into three categories: (1) Treasury bills; (2) Treasury notes; and (3) Treasury bonds. They each have a different length of time until maturity. Income earned on Treasuries is exempt from state and local taxes, but taxable by the federal government. Treasuries are considered the safest bond investments since the U.S. government backs them and it is highly unlikely that a situation of default will occur. However, Treasuries with longer maturities generally have higher interest rate and credit risk.

2. Municipal Bonds

Municipal bonds are debt obligations of state or local governments. The funds may be used to support general governmental needs or special projects. Municipal bonds are considered riskier investments than Treasuries. They generally are exempt from federal taxation, and state or local government issuers often exempt their own citizens from taxes. However, municipal bonds often pay a lower interest rate because of their favorable tax treatment. When considering an investment in municipal bonds, bear in mind that no two municipal bonds issues are exactly alike, so it is important to carefully evaluate up-to-date information about both the bond and its issuer.

3. Corporate Bonds

Companies issue corporate bonds (or corporates) to raise money for capital expenditures, operations and acquisitions. Corporates are issued by all types of businesses. Corporate bonds are debt instruments issued by private corporations. There are many types of corporate bonds, and investors have a wide range of choices with respect to bond structures, coupon rates, maturity dates and credit quality, among other characteristics.

Corporate bonds tend to be categorized as either investment grade or non-investment grade. Non-investment grade bonds are also referred to as "high yield" bonds because they tend to pay higher yields than Treasuries and investment-grade corporate bonds. However, with this higher yield comes a higher level of risk. High yield bonds also go by another name: junk bonds.

Par value, or face amount, is usually $1,000, but bond prices are quoted in $100. For example, a quote of 80 is a bond selling for $800. Amounts less than $10 are quoted in eighths ($1.25). Therefore, a quote of 80 1/8 is equal to $801.25.

Most corporate bonds trade in the over-the-counter (OTC) market. The OTC market for corporates is decentralized, with bond dealers and brokers trading with each other around the country over the phone or electronically.

Convertible Bonds are bonds that may be converted into another form of corporate security, usually shares of common stock. Conversion only occurs at specific times at specific prices under specific conditions and this will all be detailed at the time the bond is issued

4. Zero-Coupon Bonds

These are bonds that do not pay interest periodically, but instead pay a lump sum of the principal and interest at maturity. Investors, however, must pay taxes on the interest as it accrues, not when they receive it.

5. Sovereign Bonds

A sovereign bond is a specific debt instrument issued by a government outside of the United States. They can be denominated in both foreign and domestic currency. Similar to other bonds, these generally pay the buyer a certain amount of interest for a stipulated number of years and repay the face value on maturity

How are Bonds Rated?

Standard & Poor's and Moody's Investors Service assign credit ratings to governments and corporations which help determine the amount of interest paid. The ratings for bonds are in the chart below. The ratings represent greater default risk as you read down the chart (see Section 2 for credit and other risks associated with bonds).

Quality	Moody's	Standard & Poor's
Best Quality	Aaa	AAA
High Quality	Aa	AA
Upper-medium grade	A	A
Medium grade	Baa	BBB
Junk Bonds/Speculative/High Yield	Ba, B, Caa, Ca	BB, B, CCC, CC
Default	-	D

Bond ratings are subject to change by factors that affect the company's credit.

The ratings that appear for the bonds IB offers are from sources IB believes to be reliable; however, IB cannot guarantee their accuracy.

2. General Risks of Bond Trading

Trading bonds may not be suitable for all investors. Although bonds are often thought to be conservative investments, there numerous risks involved in bond trading. If you are uncomfortable with any of the risks involved, you should not trade bonds

Credit Risk. There is a credit risk involved with trading bonds. When you purchase a bond, you are lending money to the issuer. There is always the risk that the issuer will go bankrupt or otherwise be unable to make payments when they are due. If this happens, you may lose some or all of your investment.

Prepayment risk. Prepayment or "call" risk involves the scenario where an issuer "calls" a bond. If this happens, your investment will be paid back early and you may not be able to locate an alternative bond with similar terms. Certain bonds are callable and others are not, and this information is detailed in the prospectus. If a bond is callable, the prospectus will detail a "yield-to-call" figure. Corporations may call their bonds when interest rates fall below current bond rates.

A "put" provision allows a bondholder to redeem a bond at par value before it matures. Investors may do this when interest rates are rising and they can get higher rates elsewhere. The issuer will assign specific dates to take advantage of a put provision. Prepayment risk is figured into the pricing of bonds.

Inflation Risk. Inflation risk is the risk that the rate of the yield to call or maturity of the bond will not provide a positive return over the rate of inflation for the period of the investment. In other words, if the rate of inflation for the period of an investment is six percent and the yield to maturity of a bond is four percent, you will receive more money in interest and principal than you invested, but the value of that money returned is actually less than what was originally invested in the bond. As the inflation rate rises, so do interest rates. Although the yield on the bond increases, the price of the actual bond decreases.

Interest Rate Risk. Interest rate risk is the potential for investment losses that result from a change in interest rates. If interest rates rise, for instance, the value of a bond or other fixed-income investment will decline.

Liquidity Risk. Liquidity risk is the risk that you will not be easily able to find a buyer for a bond you need to sell. If there is a limited or no secondary market for bonds you hold, the sale price may be much lower than the amount invested or the amount you may receive if you hold the bond to maturity.

3. Risks of Trading Bonds Electronically

IBKR is an online, direct access brokerage firm that executes virtually all trades on electronic market centers. IBKR will post bids and offers for bonds from various information sources and markets and will allow you to execute trades against those electronically-displayed bond quotes.

Unlike the practice of many other brokers, IBKR typically does not make telephone calls to various bond dealers in seeking to execute your bond orders. Rather, IBKR will provide you with direct access to electronic bond trading platforms.

Electronic trading has a number of inherent advantages (such as speed, low cost, and a clear audit trail) but it also has certain inherent disadvantages. You should be aware that electronic bond trading platforms may have less liquidity or less advantageous prices than could be offered telephonically by a bond dealer. In addition, electronic trading platforms are inherently vulnerable to technical errors and outages.

Please note that many bond dealers place quotes to buy or sell the same bond position on multiple bond trading venues (e.g., 10 bonds on Market A and 10 bonds on Market B). If an IB customer order executes against both of the quotes (e.g., an order to buy 20 is filled 10 at Market A and 10 at Market B), the dealer may request that one of the trades be busted (reversed). IBKR reserves the right to grant such requests without consent of customer if IBKR, in its discretion, believes that the dealer is acting in good faith.

4. Risks Specific to Distressed Bonds

Distressed bonds generally are bonds of a company which has either defaulted, is under bankruptcy protection, or is in financial distress and moving toward bankruptcy or default in the near future. Distressed bonds frequently trade "flat," meaning that the buyer of the bond is not responsible for paying the interest that has accrued since the last payment. In effect, a flat bond is a bond that is trading without the accrued interest. The price of a flat bond is referred to as the "flat price" or "clean price." Typically, flat prices are quoted so as not to misrepresent the daily increase in the dirty price (bond price plus accrued interest) since accrued interest does not change the yield to maturity (YTM) of the bond.

On the Settlement Date, the buyer must pay to seller only the agreed upon price, without any payment in respect of interest. The person holding the bond on the Record Date receives any and all interest payments whenever made. If a Record Date occurs before the Settlement Date, seller will get any interest paid on a bond that is trading Flat. If there is a change in the Record Date, the party that was a bondholder with respect to the prior Record Date loses any rights they may have had to receive any related payment of principal or interest.

If a bond that was sold with accrued interest begins trading Flat after the trade date, but before Settlement date, the buyer remains responsible for paying the accrued interest to the seller, even though the buyer may not receive interest from the bond issuer. If the accrued interest payment is not made on the actual Payment Date, but is made during the Grace Period, any interest payments will accrue to the seller. If accrued interest is paid after the Grace Period, it will belong to the buyer when paid.

Bankruptcy courts can issue broad orders at the request of a bankruptcy debtor that halt or seriously restrict trading in all of the debt and equity of the debtor corporation for the protection of the bankruptcy debtor's net operating loss ("NOL") carryovers and other tax attributes of the debtor.

"Minimum denomination transfer requirements" are generally found in the Indenture and the offering documents and provide that a transfer of a bond whether in physical or book- entry form be made in certain minimum denominations.

Clients should be aware that bonds may begin trading flat before a legal default occurs. In this scenario, brokers anticipate the default occurring and the market and dealers will trade bonds without Accrued Interest even though the issuer has not missed an interest payment.

5. Risks of Utilizing the IBKR Bond Desk

Clients that utilize the IBKR bond desk should be aware of the risks inherent with trading bonds in the traditional (non-electronic) manner. The bond desk provides clients with assisted bond trading where a designated bond trader works with customers to find liquidity that in not available on IBKR's electronic bond trading platforms. To identify the liquidity, the trader will communicate with other bond dealers to find bonds and/or pricing that align with the customer's request.

When the bond desk agrees to work a client's order, we are only indicating a willingness to attempt to identify a counterparty to the trade requested by the client and are not obliged to enter into any transaction or guaranteeing the full or partial execution of such order.

IBKR's experienced bond traders will exercise their discretion in deciding whether to work the order, which orders we are willing to execute and when and how to execute all or any part of an order. When IBKR agrees to work an order over a period of time or otherwise to accept an order involving the exercise of discretion, IBKR will attempt to exercise this discretion reasonably and fairly, but, unless otherwise agreed, IBKR is not committed to executing all or any part of the order in any particular way. Clients requesting that IBKR work orders in foreign markets should be aware that bond traders may work orders outside of U.S. trading hours.

6. Margin

When a broker-dealer lends a customer part of the funds needed to purchase a security, such as a bond, the term "margin" refers to the amount of cash, or down payment, the customer is required to deposit. Bonds, like equity securities, may be traded on margin. Trading on margin is inherently more risky than trading in fully-paid-for securities. For risks associated with margin trading, please see Interactive Brokers “Disclosure of Risks of Margin Trading.”

7. Commissions and Mark-Ups

You will be charged a commission for bond trades executed through IBKR. IBKR may execute your bond trade through or against an affiliate of IBKR, which may charge a markup on trades such affiliate executes as principal against your bond order

Interactive Brokers General Disclosure on Mutual Funds

Important Information Regarding Mutual Funds

1. Interactive Brokers ("IB") offers customers the ability to invest in certain mutual funds. By making a mutual fund or mutual fund family available to customers, IB does not guarantee the appropriateness or suitability of any mutual fund investment nor do we make any recommendation of any kind.
2. A mutual fund’s past performance is no indication of future results. A mutual fund’s performance can change over time depending upon a variety of market conditions and share prices can fluctuate on a daily basis. Your investment may be worth more or less than your original cost when you redeem your shares.
3. IB recommends that customers carefully read the fund's prospectus prior to investing in the shares of a mutual fund. The prospectus contains important information about the fund's objectives, investment strategies, risks and expenses. Customers may obtain a copy of a fund's prospectus by contacting the fund or visiting the fund's website. Customers may also contact IB Customer Service at (877) 442-2757 to request a prospectus. Please note, IB cannot verify or otherwise guarantee the accuracy or completeness of any mutual fund prospectus, statement of additional information, report to shareholders or proxy solicitation materials.
4. Certain mutual funds made available through IB invest in international securities. Internationally invested mutual funds can carry certain risks, including, but not limited to, political and economic instability, fluctuations in currency exchange rates, foreign taxes, and differences in regulatory requirements and financial accounting standards. Prior to making an investment decision, customers are encouraged to carefully read the prospectus of any mutual fund that invests internationally.
5. Some funds may require a minimum holding period for their shares. Some funds charge an early redemption fee if they are sold before a stated holding period ends. Please refer to the fund's prospectus to see if these conditions apply.
6. As a mutual fund shareholder, you may receive taxable dividends and/or capital gains on your mutual fund investment. IB does not provide tax advice. Mutual fund investors should consult with their tax advisor in order to determine the impact of taxes on their mutual fund investment.
7. In addition to Interactive Broker's transaction fee for mutual fund transactions, some mutual funds impose marketing and shareholder servicing fees (e.g., 12b-1 fees). Interactive Brokers may receive a portion of these fees as compensation for shareholder and marketing services rendered. For information regarding a particular mutual fund's payment and compensation practices, please read the fund's prospectus and statement of additional information or visit the fund's website. IB may share a portion of the compensation received from fund companies with your financial advisor.
8. Mutual Fund Order Deadline. Please note that all mutual fund orders for U.S. based funds received prior to the exchange close (generally, 4:00 p.m. EST) will receive the mutual fund's NAV share price for that day provided the order is received on a trading day. Any mutual fund orders for U.S. based funds received after the close of the exchange will receive the following trading day's NAV share price. Any mutual fund orders for U.S. based funds received on days when the New York Stock Exchange is closed (e.g., holidays) will receive the following trading day's NAV share price.

   All mutual fund orders for non-U.S. based funds received prior to the order deadline specified in the fund's prospectus or as determined by IB or any other intermediary will receive the mutual fund's NAV price for that day provided the order is received on a trading day. Any mutual fund orders for non-U.S. based funds received after the order deadline specified in the fund's prospectus or as determined by IB or any other intermediary will receive the following trading day's NAV share price. Any mutual fund orders for non-U.S. based funds received on days when the local market is closed (e.g., holidays) will receive the following trading day's NAV share price.

   IB or another mutual fund intermediary may set an order deadline earlier than the time stated in the fund's prospectus to accommodate processing.

9. Order Cancelations or Corrections. Mutual funds are not exchange traded products and subscriptions/redemptions are processed once per day by the fund or its agents. Each fund has a cut-off time, after which an instruction to subscribe or redeem cannot go through until the next day. Any attempt to cancel or modify an order is considered a request that IB will do its best to meet. However, IB cannot guarantee that such cancelation or modification requests will be processed, even where the request is submitted before the cut off time. You remain responsible for executions even where you have made a request to cancel or modify an order, and IB is not liable to you if we are unable to fulfil your request to cancel or modify an order.

Interactive Brokers Municipal Securities Disclosure

Interactive Brokers LLC

Interactive Brokers LLC is registered with the U.S. Securities and Exchange Commission and the Municipal Securities Rulemaking Board ("MSRB"). We encourage you to review the information available from The Financial Industry Regulatory Authority (FINRA) at www.finra.org and the MSRB at www.msrb.org regarding the trading of municipal securities. We have included links to specific information and documents available on these websites that you should review and be familiar with before trading municipal securities.

FINRA Rules and Guidance: https://www.finra.org/rules-guidance/key-topics/municipal-securities

MSRB Brochure: Information for Municipal Securities Investors

Penny Stock Trading Risk Disclosure

This disclosure contains additional important information regarding the characteristics and risks associated with trading small-cap (penny) stocks.

What is a "Penny" Stock?

Generally, penny stocks are low-priced shares of small companies that are not traded on an exchange or quoted on NASDAQ. Penny stocks generally are traded over-the-counter, such as on the OTC Bulletin Board or Pink Sheets, and are historically more volatile and less liquid than other equities. For these and other reasons, penny stocks are considered speculative investments and customers who trade in penny stocks should be prepared for the possibility that they may lose their entire investment, or an amount in excess of their investment if they purchased penny stocks on margin. Before investing in a penny stock, you should thoroughly review the company issuing the penny stock. In addition, you should be aware of certain specific risks associated with trading in penny stocks.

Risks Associated With Penny Stocks

There are a number of risks of trading penny stocks, including the following:

You Can Lose All or Much of Your Investment Trading Penny Stocks. All investments involve risk but penny stocks are among the most risky and are generally not appropriate for investors with low risk tolerance. Many penny stock companies are new and do not have a proven track record. Some penny stock companies have no assets, operations or revenues. Others have products and services that are still in development or have yet to be tested in the market. Penny stock companies therefore have a greater risk of failure and those who invest in penny stocks have a greater risk that they may lose some or all of their investment.

Lack of Publicly Available Information. Most large, publicly-traded companies file periodic reports with the SEC that provide information relating to the company's assets, liabilities and performance over time. In addition, these companies provide their financial information and operational results online. In contrast, information about penny stock companies can be extremely difficult to find, making them more likely to be the subject of an investment fraud scheme and making it less likely that quoted prices in the market will be based on full and complete information about the company.

No Minimum Listing Standards. Companies that offer shares of their stock on exchanges can be subject to stringent listing standards that require the company to have a minimum amount of net assets and shareholders. Most penny stock companies do not list their shares on exchanges and are not subject to these minimum standards.

Risk of Lower Liquidity. Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more demand there is for a particular security, the greater the liquidity for that security. Greater liquidity makes it easier for investors to buy or sell securities so investors are more likely to receive a competitive price for securities purchased or sold if the security is more liquid. Penny stocks are often traded infrequently and have lower liquidity. You may therefore have difficulty selling penny stocks once you own them. Moreover, because it may be difficult to find quotations for certain penny stocks, they may be difficult, or even impossible, to accurately price.

Risk of Higher Volatility. Volatility refers to changes in price that securities undergo when they are being traded. Generally, the higher the volatility of a security, the greater its price swings. Due to their lower liquidity, penny stocks are subject to greater volatility and price swings. A customer order to purchase or sell a penny stock may not execute or may execute at a substantially different price than the prices quoted in the market at the time the order was placed. In addition, the market price of any penny stock shares you obtain can vary significantly over time.

Penny Stocks Can Be Subject to Scams. Penny stocks are frequent vehicles for scams and/or market manipulation due to their generally lower prices and less stringent listing requirements. You should be wary of advertisements, unsolicited e-mails, newsletters, blogs or other promotional reports that emphasize the potential for large profits in penny stocks generally or certain penny stocks. These promotional materials are often used to manipulate or "pump up" the price of penny stocks before selling a large volume of shares. Customers are therefore strongly encouraged to do their own due diligence with respect to any penny stock company they invest in and to not rely on any outside promotional reports or newsletters.

Further information concerning penny stocks and the risks involved in trading them is available on the SEC's website at http://www.sec.gov/investor/pubs/microcapstock.htm. Please also review our Risk Disclosure Regarding Ramp and Dump Scams for additional information on scams you may encounter trading Penny Stocks.

Important Characteristics and Risks of Participating in Interactive Brokers LLC's Fully-Paid Securities Lending Program

You should read these disclosures together with the (i) Interactive Brokers Master Securities Lending Agreement for Fully-Paid Lending Program (the "Agreement") and the (ii) Securities Account Control Agreement (the "Collateral Agreement") carefully before deciding to participate in IB's Fully-Paid Securities Lending Program.

Introduction

Interactive Brokers LLC ("IB") offers eligible customers the ability to lend certain of their fully paid and excess margin securities to IB for on-lending to other IB customers or to other market participants who wish to use these shares for short selling, to make required deliveries or other purposes. "Fully-paid securities" are securities in your account that have been completely paid for. "Excess-margin securities" are any securities in your account that, in aggregate, have a market value that exceeds 140% of your account's debit balance(s). In this disclosure and in the relevant agreements, we collectively refer to fully-paid and excess margin securities as "Fully-Paid Securities" or "Fully-Paid Shares". Lending your Fully-Paid Shares may be a way to increase the yield on your portfolio, because some shares are in high demand in the securities-lending market and borrowers are willing to pay for the use of your shares.

Securities Loaned Out By You May Not Be Protected by SIPC

The provisions of the Securities Investor Protection Act of 1970 ("SIPA") may not protect you as a lender with respect to securities loan transactions in which you lend your Fully-Paid Securities to IB. Therefore, the collateral delivered to you (and indicated on your account statement) may constitute the only source of satisfaction of IB's obligation in the event that IB fails to return the securities.

Stock Yield Enhancement Program: In the IB Stock Yield Enhancement Program, you permit IB to borrow any Fully-Paid Securities in your account and loan these securities out in the securities lending market. By participating in the IB Stock Yield Enhancement Program, you are granting to IB the discretion to borrow your Fully-Paid Securities without contacting you, obtaining your prior approval of any given loan or the amount of interest you will be paid for lending your Fully-Paid Securities. You will still be able to sell any securities in your account at any time, regardless whether they are currently on loan to IB. You will also be able to terminate your participation in the Stock Yield Enhancement Program at any time, automatically terminating any outstanding loans of Fully-Paid Securities. IB will pay you interest in connection with its borrowing of your Fully-Paid Securities. The interest rate IB pays you will approximate a percentage of the net income received by IB for lending your securities. IB's net income may be less than the gross income received by IB for relending your securities because of certain deductions and charges, as explained below. IB may make certain assumptions in computing the net amounts.

Basic Mechanics of a Fully-Paid Lending Transaction

When the lending transaction takes place, the securities borrowed will be debited from your account, though they will still be reflected on your account statements as securities on loan to IB. IB will provide you with collateral to secure IB's obligation to return the securities upon termination of the loan.

By participating in the Stock Yield Enhancement Program, you are not lending your Fully-Paid Securities directly to the ultimate borrower. IB will be the borrower in respect of each loan and will be responsible as principal for returning your securities to you upon termination of the loan, providing you collateral during the term of the loan and paying you interest monthly in respect of securities loaned to IB.

Securities Loaned Out by You Are Typically Used to Facilitate Short Sales

The type of securities that are generally attractive to borrowers in the securities lending market, and which generate the highest income potential, are "hard to borrow" securities. When you lend your Fully-Paid Securities, it is likely that such securities will be used to facilitate one or more short sales or satisfy delivery requirements resulting from short sales. Since you are holding the shares "long" in your account, the activity of short sellers potentially could affect the value of your holdings. You may elect not to permit securities that are the subject of a loan to be used in connection with a short sale of the subject securities. If you elect not to permit your securities to be used in connection with a short sale of the subject securities, IB will terminate any then-outstanding loan and un-enroll your account from the Stock Yield Enhancement Program to prevent the borrowing of the security for that purpose. If you do not want your fully-paid securities used to facilitate short sales, you should NOT participate in IB's Fully Paid Securities Lending Program.

You Continue to Own Loaned Shares and Have Market Risk on Those Shares

When you lend securities to IB, you continue to own the securities and you continue to have the market exposure inherent in ownership of the securities (i.e., if the share price increases while you own the shares but are lending them out, the value of the securities you are entitled to receive back upon termination of the loan will increase; if the share price goes down, the value of the securities you are entitled to receive back upon termination of the loan will decrease).

You Can Sell Your Loaned Securities At Any Time

Even though you have loaned your securities out, you can sell those securities at any time, just like any other securities in your IB account. Your sale of the securities will constitute a termination of the loan effective on the settlement date of the sale. You do not have to take any other action to terminate the loan or wait for the shares to be returned prior to selling them. Even if the shares are not returned in time to settle your sale of the shares, IB will be responsible for settling the sale, not you, and you will receive the proceeds from the sale of the shares on the normal settlement date for the sale.

Collateral for Loaned Securities

Pursuant to the Agreement, in exchange for the loaned securities, IB will deliver collateral to you. Collateral provided to you in respect of loaned securities will consist of cash and/or U.S. Treasury securities deposited in an account (the "Pledge Account") carried by IBKR Securities Services LLC (the "Securities Intermediary"), an affiliate of IB registered as a broker-dealer pursuant to section 15 of the Securities Exchange Act of 1934, as amended. The Securities Intermediary establishes the Pledge Account in the name of IB pledged for your benefit. Pursuant to the Agreement, funds and securities deposited in the Pledge Account are pledged as collateral to secure IB's obligation to return loaned securities to you. The Securities Intermediary, in accordance with the terms of the Collateral Agreement, maintains the Pledge Account and, in the event of an uncured default by IB, upon delivery of a notice of exclusive control by you to the Securities Intermediary, will accept instructions from you to deliver the collateral to you.

Prior to any delivery by you of a notice of exclusive control, pursuant to the Agreement and the Collateral Agreement, you authorize IB to make deposits to and withdrawals from the Pledge Account without further consent by you. Pursuant to the Agreement and applicable regulations, IB will mark the loaned securities to market at the close of trading on each business day and, if necessary, will either provide you additional collateral or withdraw excess collateral on the next business day so that the market value of the collateral is at least equal to 100% of the prior day's market value of the loaned securities. There is the risk that IB will default in some way, for example by becoming insolvent, which could result in IB failing to return borrowed securities to you. If IB's default results from something other than an act of insolvency, IB will have the right to cure that default.

If IB defaults and the market value of the loaned securities increases in value, the collateral provided by IB may be insufficient to fully collateralize the loaned securities. Because it acts as the custodian of the collateral in the Pledge Account, you may also be impacted by any default or insolvency of the Securities Intermediary. The most recent statement of financial condition of the Securities Intermediary is available at https://www.interactivebrokers.com/en/index.php?f=289.

You will not receive separate notices from the Securities Intermediary with respect to deposits to and withdrawals from the Pledge Account. Your IB account statement will reflect the current cash balance and U.S. Treasury securities custodied in the Pledge Account as of the statement date and will reflect all deposits to and withdrawals from the Pledge Account during the statement period. You may obtain information about the Pledge Account and confirm balances and positions in the Pledge Account directly with Securities Intermediary by email to ibkrss_saca_questions@ibkr.com.

You have a lien on collateral held in the Pledge Account granted to you under the Agreement, but you do not own the collateral and are not entitled to any market price increase in the collateral. The collateral must be returned to IB upon termination of the securities loan. A portion of the collateral will count as "buying power" for your IB securities account, however, neither the collateral in the Pledge Account nor any loaned securities will count as "equity" in your IB account for the purposes of initial margin or maintenance margin under the margin rules, including Regulation T of the Board of Governors of the Federal Reserve System and Rule 4210 of the Financial Industry Regulatory Authority.

Loan Rates (and therefore the Interest Rate You Will Receive) Are Subject to Frequent Change and Can Go Down (or Up) Significantly

Rates for "hard to borrow" and other securities change frequently, even daily, in the securities-lending market and this can reduce (or increase) the loan interest IB pays you. Likewise, IB may change the rate it pays you compared to the income that IB receives when it lends your securities to third parties. You will not have direct control over when to initiate or terminate loans of specific shares (including based on rate changes). However, you can always terminate your participation in the program (which will terminate all of your lending transactions) if you are unhappy with the interest rates you are receiving or the nature or frequency of rate changes. Please note, though, that if you terminate your participation in the Stock Yield Enhancement Program, you may not be permitted to re-join the program, or you may have to wait a certain length of time to re-join.

Potential Adverse Tax Consequences from Receiving Substitute Payments or Payments in Lieu of Distributions on Loaned Securities ¹

When you lend your Fully-Paid Securities, you will be entitled to receive all distributions (as that term is defined in the Agreement) made on or in respect of the securities, such as cash or securities dividends, interest payments, securities received as a result of splits, spin-offs or similar distributions, and rights to purchase additional securities. In the event that the holder of a security borrowed from you is entitled to elect the type of distribution to be received from two or more alternatives, you shall be entitled to make such election by timely notification to IB. However, you will receive substitute payments (e.g., a cash substitute payment) in lieu of receiving dividends or other types of distributions directly from the issuer. Certain unique distributions may not be capable of being exactly replicated as a manufactured payment by IB. For example, cash payments in lieu of dividends may not be afforded the same treatment as qualified dividends for tax purposes and are likely to be taxed at a higher tax rate for U.S. taxpayers instead of the preferential qualified dividend rate. Special tax considerations may apply to loans of master limited partnerships, publicly traded partnerships or other securities with pass-through tax characteristics. IB may be required to withhold tax on payments in lieu of dividends on U.S. and foreign stocks and loan interest paid to you unless an exception applies. IB intends to treat the loan interest payments to you as interest payments, but different tax authorities may treat such payments differently.

You should consult a tax advisor regarding the tax implications of entering into the Agreement and lending securities to IB, the receipt of substitute payments under applicable federal, state and local tax laws, as well as any foreign tax regulations, circumstances where a securities loan could be treated as a taxable disposition of the loaned securities, and treatment of loan interest.

If you permit IB to borrow securities from you through the IB Stock Yield Enhancement Program and you are a U.S. taxpayer, IB may recall loaned shares from the borrower prior to a dividend, so as to reduce potential negative tax consequences to you. However, it is solely within IB's discretion to recall a loan and IB makes no guarantee it will recall a loan prior to a dividend. With respect to other corporate actions affecting loaned shares, non-cash distributions that you are entitled to receive in connection with ownership of loaned securities will be added to the loaned securities on the date of distribution and will be transferred to you at termination of the loan.

Loan Termination

IB may terminate your loan at any time in its sole discretion. When the loan is terminated, shares will be returned to your account. If you permit IB to borrow securities through the IB Stock Yield Enhancement Program, you will not have direct control over when to initiate loans of specific shares or when IB may choose to terminate any loan. You may terminate a loan at any time by selling the security that is the subject of the loan or requesting delivery or transfer of the security to another custodian. Under the terms of the Agreement, you may also terminate a loan by notice to IB; please note, however, that if the security remains in your account with IB and your account remains enrolled in the IB Stock Yield Enhancement Program, the security may be promptly re-borrowed by IB. If you would like to terminate a loan and prevent it from being reborrowed by IB, you can terminate your participation in the program (which will terminate all of your lending transactions) by unenrolling under "Stock Yield Enhancement Program" within the "Account Settings" section of the Client Portal.

Conflicts; Non-Exclusive Arrangement; IB Discretion to Borrow; Payments to Third Parties

IB is not required to borrow your securities and may, in its sole discretion, borrow from other parties securities equivalent to securities available to be borrowed from you. IB's choices both on the securities it borrows and how it chooses to use those securities impact the loan interest payable by IB to you. If you participate in the Stock Yield Enhancement Program and maintain a debit balance in your account, IB may rehypothecate your securities in accordance with your margin account agreement with IB without paying you loan interest, rather than borrow your securities pursuant to the Agreement. Similarly, if IB borrows securities from you pursuant to the Agreement and you thereafter incur a margin debit balance, IB may terminate the Loan and then rehypothecate the securities that had previously been the subject of a loan without paying you loan interest. IB may pay part of the loan income it earns on shares borrowed from you to third parties such as your financial advisor or introducing broker who may introduce your account to IB. These payments may reduce the interest rate you receive for the entire duration of the loan.

Key Factors Influencing the Amount of Compensation IB May Earn

The key factors that influence the amount of compensation IB may earn from borrowing securities loaned by you are (i) the availability of the securities for lending in the marketplace relative to the demand to borrow such securities; (ii) then-current interest rates, which impact what IB may earn from re-investing cash collateral received from counterparties to which it lends securities; (iii) commissions, interest and other fees IB may earn from customers that borrow securities from IB to sell short through IB or in accounts carried by IB.

Key Factors Influencing Loan Interest Paid to You

You will be paid loan interest by IB for the loan of your securities. The interest payable to you in respect of any particular loan as of a given date is detailed on your daily account statement. You will not receive any portion of any other compensation IB may earn in connection with the re-lending of your securities, including, without limitation, any interest IB may earn on collateral provided to you, any interest IB may earn on collateral provided to it by counterparties to which it re-lends the loaned securities, any fees IB may earn from counterparties to which it re-lends the loaned securities, or any commissions IB may receive in connection with any executions of transactions for the account of parties that borrow securities from IB. The key factors that influence the amount of loan interest paid to you is (i) the availability of the securities for lending in the marketplace relative to the demand to borrow such securities; (ii) the average loan interest earned by IB in lending securities of the same class to third parties during the term of your loan; (iii) current interest rates; and (iv) whether IB shares a portion of the compensation it earns from re-lending securities borrowed from you with a third party such as your introducing broker or financial advisor. The loan interest rate may be changed from time to time in IB's sole discretion and different rates may be paid to different customers based on a variety of factors, including the size of the customers' loan portfolios and the types of Fully-Paid Securities available in the customers' accounts. If you participate in the IB Stock Yield Enhancement Program and IB borrows your Fully-Paid Securities, IB will accrue interest for your account daily and credit your account with the loan interest monthly.

There Is No Guarantee That You Will Receive the Best Loan Rates for Your Shares The securities lending market is not a standardized or transparent market. Securities lending transactions generally take place "over the counter" rather than on organized exchanges where prices and transactions are transparent. IB cannot and does not guarantee that it will pay the highest rate for borrowing your shares. IB may not have access to the markets or counterparties that are offering the most favorable rates, or may be unaware of the most favorable rates. IB, or its affiliates through which it conducts certain securities-lending activities, will typically receive a higher rate from its securities-lending counterparties than it pays to you for the loan of your securities, thus earning a spread. You may always terminate your participation in the program if you are unhappy with the rates you are receiving.

Loss of Voting Rights With Respect to Loaned Securities

You may lose the right to vote, or to provide any consent or to take any similar action with respect to, loaned securities in the event that the record date or deadline for such vote, consent, or other action falls during the term of any loan.

IB's Right to Liquidate Securities Upon Your Default

IB will have the right to liquidate any securities loan upon an event of Default (as that term is defined in the Agreement) by you, which include, without limitation, your: (a) applying for or consenting to, or becoming the subject of an application for, the appointment of or the taking of possession by a receiver, custodian, trustee, or liquidator of all or a substantial part of your property; (b) admitting in writing your inability, or becoming generally unable, to pay your debts as such debts become due; (c) making a general assignment for the benefit of your creditors; or (d) filing, or having filed against you, a petition under Title 11 of the United States Code (the Bankruptcy Code), or having filed against you an application for a protective decree under Section 5 of SIPA, unless the right to liquidate such transaction is stayed, avoided, or otherwise limited by an order authorized under the provisions of SIPA or any statute administered by the SEC.

NOTES

1. IB does not provide any investment, tax or trading advice. The information in this paragraph is general information only and does not take into account your personal circumstances. You should speak to an independent tax expert to understand the tax implication to you (if any) as a result of participating in the program.

Notice Regarding NFAs BASIC System

Interactive Brokers LLC ("IB") is required to inform its customers of the National Futures Association ("NFA") Background Affiliation Status Information Center ("BASIC"). The BASIC system compiles various information on registrants and anyone can access this system on the Internet.

The information in the BASIC system includes Commodity Futures Trading Commission ("CFTC") registration information and membership information from the NFA. Also included are regulatory and non-regulatory actions contributed by the NFA, the CFTC and the U.S. futures exchanges regarding futures-related activity.

The NFA BASIC system may be accessed at http://www.nfa.futures.org/basicnet/. To locate information on a registrant, simply enter the registrant's NFA ID number when prompted. For questions regarding this system, you may contact the NFA information center at 312-781-1410 or 1-800-621-3570 between the hours of 8:00 a.m. to 5:00 p.m. CST or by email at information@nfa.futures.org.

Interactive Brokers Group Privacy Policy

At Interactive Brokers, we understand that confidentiality and security of the personal information ("Personal Information") that you share with us is important. The Interactive Brokers Group affiliates (collectively, "IBKR"), are committed to protecting the privacy of Personal Information, including Personal Information related to individuals who may be clients, employees, agents, job applicants or others inside or outside of IBKR. That is why we have developed specific policies and practices designed to protect the privacy of your Personal Information. By opening an account at IBKR or by utilizing the products, services and applications available through IBKR, you have consented to the collection, use and disclosure of your Personal Information in accordance with this privacy policy ("Privacy Policy" or "Policy"). We encourage you to read this Privacy Policy carefully.

This Policy is based on the privacy and data protection principles common to the countries in which we operate. This Policy is intended to summarize IBKR's data protection practices generally and to advise our clients, prospective clients, job applicants, website visitors and other third parties about IBKR's privacy policies that may be applicable to them.

This Policy is specifically addressed to those who provide Personal Information to IBKR or who visit or use IBKR's websites, trading platforms, software application and social media sites.

Who is responsible for your Personal Information?

IBKR is responsible for the Personal Information that we may collect in the manner discussed below. IBKR includes: Interactive Brokers LLC, One Pickwick Plaza, Greenwich, CT 06830 United States; Interactive Brokers (U.K.) Limited, 20 Fenchurch Street, Floor 12, London, EC3M 3BY, United Kingdom; Interactive Brokers Ireland Limited, North Dock One, 91/92 North Wall Quay, Dublin 1 D01 H7V7, Ireland; Interactive Brokers Hong Kong Limited, Suite 1512, Two Pacific Place, 88 Queensway, Admiralty, Hong Kong SAR; Interactive Brokers Canada Inc., 1800 McGill College Avenue, Suite 2106, Montreal, Quebec, H3A 3J6, Canada; IBKR Financial Services AG, Gubelstrasse 28/3rd Floor, Zug, 6300, Switzerland;Interactive Brokers (U.K.) Limited (DIFC Branch), Unit 507, Level 5, Index Tower, Dubai International Financial Centre, Dubai, United Arab Emirates; and their respective affiliates (the "IBKR Entities"). Specifically, your Personal Information will be controlled by the IBKR Entity that is providing services or a communication to you. In some instances your Personal Information will be controlled by more than one IBKR Entity.

How do we collect your Personal Information and what Personal Information do we collect?

IBKR collects Personal Information from you. This may include, among other things, information:

• provided during the IBKR account application process or during use of any of IBKR's website applications (for example, your name, email address, telephone number, birth date, tax ID number, investment objectives, biometric information, etc.);
• provided when you apply for an employment opportunity with us (for example, your name, contact information and any additional information provided by you in your resume);
• acquired as a result of the transactions you conduct through the IBKR systems or in connection with services offered by IBKR (for example, if you participate in IBKR's debit card program);
• received from consumer-reporting agencies;
• collected through Internet cookies (for further information on our use of cookies, please see our Cookie Policy);
• collected from you when you use iBot, IBKR's natural language interface.

For what purposes will we use your Personal Information?

We may use your Personal Information for the following purposes ("Permitted Purposes"):

• To provide services to you in accordance with any agreement(s) you or your organization may have with us, for our own administrative, record-keeping and compliance procedures;
• To provide you or your organization with brokerage and other services available on our platforms, and/or to deal with any requests or inquiries you may have;
• To pursue legitimate interests, including to carry out, monitor and analyze our business or operations including the activities set out in this Privacy Policy;
• To enforce or apply any agreement and/or to protect our (or others') property or rights and to defend any potential claim;
• To conduct our recruiting processes (applies only to information submitted for employment applications);
• To respond to requests for information from you and to follow up with you afterwards to see if we can provide any further assistance;
• To contact you (unless you tell us that you prefer us not to) regarding features and functionality that may be of interest to you;
• To enter into or carry out contracts of various kinds;
• To conduct monitoring by us or any other person on our behalf using various methods, including: (i) the use of "intelligent" automated monitoring tools; or (ii) through random monitoring of systems, for example systematically via electronic communication recording tools; (iii) specific monitoring of systems for example in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation; or (iv) monitoring of business premises for security purposes, for example, using CCTV; or (v) data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioral patterns, interactions or preferences for analysis (including predictive analysis); and/or (vi) using other similar monitoring technology that may become available from time to time;
• For statistical purposes and for market research and product analysis and to develop and improve our products and services;
• For the purposes of preventing and detecting money-laundering, terrorism, fraud or other crimes and/or abuses of our services;
• To comply with any legal, regulatory or good practice requirement whether originating from Ireland or elsewhere (including but not limited to, the United States), and to fulfil our obligations under any reporting agreement entered into with any tax authority or revenue service(s) from time to time;
• To comply with applicable laws in any country.

We may also process your Personal Information for the following purposes (after obtaining your express consent where such consent is legally required) in accordance with your preferences:

• To communicate with you through the channels you have approved to keep you up to date on the latest developments, announcements and other information about IBKR services, products and technologies;
• To conduct client surveys, marketing campaigns, market analysis, or promotional activities;
• To collect information about your preferences to create a user profile to personalize and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).

Where legally required, with regard to marketing-related communication, we will only provide you with such information after you have opted in or had an opportunity to object and we will also provide you with the opportunity to opt out at any time if you do not wish to receive further marketing-related communication from us. We like to keep our clients, personnel and other interested parties informed of company developments, including news relating to IBKR that we believe is of interest to you. If you do not wish to receive publications or details of events or seminars that we consider may be of interest to you, please let us know by following this link: https://www.interactivebrokers.com/en/index.php?f=464. Where legally required, we will not use your Personal Information for taking any automated decisions affecting you or creating profiles other than described above.

Depending on which of the above Permitted Purposes we use your Personal Information for, we may process your Personal Information on one or more of the following legal grounds:

• Because processing is necessary for the performance of your instruction or other contract with you or to take steps prior to entering into any such contract;
• To comply with our legal obligations (for example, to keep pension records or records for tax purposes);
• Because processing is necessary for the purposes of our legitimate interest or those of any third party recipients that receive your Personal Information, provided that such interests are not overridden by your interests or fundamental rights and freedoms.

In addition, the processing may be based on your consent where we have expressly sought and you have expressly given that to us.

Who we share your Personal Information with, and in what circumstances

We share your Personal Information in the following circumstances:

• We may share your Personal Information between the IBKR Entities on a confidential basis as allowed by applicable law or where required for the purpose of providing products or services and for administrative, billing and other business purposes. A list of the countries in which IBKR Entities are located can be found on our website;
• We instruct service providers within and outside of IBKR (including cloud service providers such as AWS), domestically or abroad, to process Personal Information for the Permitted Purposes on our behalf and in accordance with our instructions and based on our legitimate interest to provide, maintain and improve our products and services. For example, if you choose to subscribe to any services provided by a third-party provider listed on an Interactive Brokers Investors' Marketplace, we may disclose such information to service providers as necessary for them to provide the services that you have requested. IBKR generally requires these service providers to enter into confidentiality agreements with IBKR that limit their use of the information that they receive. Such agreements prohibit the service provider from using IBKR client information that they receive other than to carry out the purposes for which the information was disclosed. If required by law, IBKR will retain control over and will remain responsible for your Personal Information and will use appropriate safeguards to ensure the integrity and security of your Personal Information when engaging service providers;
• We may share your Personal Information with companies providing services in the areas of fraud and crime prevention and with companies providing similar services, including financial institutions such as credit reference agencies and regulatory bodies;
• We may disclose information about you to any depository, stock exchange, clearing or settlement system, account controller or other participant in the relevant system, to counterparties, dealers, custodians, intermediaries and others where disclosure is reasonably intended for the purpose of effecting, managing or reporting transactions in connection with the provision of our services or establishing a relationship with a view to such transactions;
• We may share data provided to us for employment applications with third parties to assist us with the conduct of our recruitment processes;
• Consistent with applicable law, we may share your Personal Information with courts, law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defence of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process;
• We may also use aggregated Personal Information and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.

Otherwise, we will only disclose your Personal Information when you direct us or give us permission to do so, when we are allowed or required by applicable law or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.

Personal Information about other people that you provide to us

If you provide Personal Information to us about someone else (such as one of your directors or employees or someone with whom you have business dealings), you must ensure that you are entitled to disclose that Personal Information to us for processing as described in this Privacy Policy.

Keeping Personal Information about you secure

To the extent required by law, we will take appropriate technical and organizational measures to keep your Personal Information confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to Personal Information. Personal Information may be kept on our Information Technology systems, those of our contractors or in paper files.

Transferring your Personal Information outside the European Economic Area ("EEA") or the United Kingdom (if GDPR or UK GDPR applies), outside of the Dubai International Financial Centre ("DIFC") (if the DIFC DPL applies) or outside of Quebec (if the Quebec Private Sector Act applies)

For Personal Information subject to the General Data Protection Regulation (EU) 2016/679 ("GDPR") or the UK General Data Protection Regulation ("UK GDPR") we may transfer your Personal Information outside the EEA or the United Kingdom (the "UK") for the Permitted Purposes as described above. This may include countries that do not provide the same level of protection as the laws of your home country (for example, the laws within the EEA, the UK or the United States). We will ensure that any such international transfers are made subject to appropriate or suitable safeguards if required by the GDPR, UK GDPR or other relevant laws. You may contact us at any time using the contact details below if you would like further information on such safeguards.

With respect to persons covered by GDPR, in case Personal Information is transferred to countries or territories outside of the EEA, or in the case of UK GDPR outside of the UK, that are not recognized by the European Commission as offering an adequate level of data protection, we have put in place appropriate data transfer mechanisms to ensure Personal Information is protected.

With respect to persons covered by the Data Protection Law, DIFC Law No. 5 of 2020, as amended, ("DIFC DPL"), in case Personal Information is transferred to countries or territories outside of the DIFC, that are not recognized by the DIFC Commissioner of Data Protection as offering an adequate level of data protection, we have put in place appropriate data transfer mechanisms to ensure Personal Information is protected, including ensuring DIFC-specific standard contractual clauses are in place. For Personal Information subject to the Act Respecting the Protection of Personal Information in the Private Sector (“the Quebec Private Sector Act”), your Personal Information may be shared and transferred outside of Quebec to third parties who are based in other provinces in Canada or in countries outside of Canada. We will ensure that any such transfers are made subject to appropriate or suitable safeguards if required by the Quebec Private Sector Act or other relevant laws.

If you have any questions about this section and/or appropriate data transfer mechanism used by IBKR, please contact the Data Protection Officer at dpo@ibkr.com.

Updating your Personal Information

If any of the Personal Information that you have provided to us changes, for example if you change your email address or if you wish to cancel any request that you have made of us, please let us know by contacting IBKR Client Service through the IBKR website at ibkr.com/help. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Information that you provide to us.

How long do we retain your Personal Information?

We retain your Personal Information in an identifiable form in accordance with our internal policies which establish general standards and procedures regarding the retention, handling and disposition of your Personal Information. Personal Information is retained for as long as necessary to meet legal, regulatory and business requirements. Retention periods may be extended if we are required to preserve your Personal Information in connection with litigation, investigations and proceedings.

Further rights for persons or information covered by GDPR, UK GDPR, the Personal Information Protection Law ("PIPL"), DIFC DPL, and the Quebec Private Sector Act

With respect to residents of the EEA, the UK, the People's Republic of China ("PRC"), DIFC, and Quebec, as well as in situations where your Personal Information is processed by an IBKR Entity established in the EEA, the UK, DIFC, Quebec or any other applicable jurisdictions ("Covered Individuals"), you have a number of legal rights under GDPR, UK GDPR, PIPL, DIFC DPL, and/or the Quebec Private Sector Act in relation to the Personal Information that we hold about you. These rights include:

• Obtaining information regarding the processing of your personal information and access to the personal information that we hold about you. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information, (in particular, information that is subject to legal professional privilege);
• Requesting that we correct your personal information if it is inaccurate or incomplete;
• Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it;
• Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request;
• Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so;
• Obtaining computerized personal information collected from you in a structured, commonly used and technological format (right to data portability).

We have designated a Data Protection Officer ("DPO") to enhance and promote compliance with and understanding of privacy and data protection principles. If you wish to do any of the above please send an email to dpo@ibkr.com.

We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorized disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data and for any additional copies of the Personal Information you request from us.

We will consider any requests or complaints that we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you may take your complaint to the relevant privacy regulator. We will provide you with details of your relevant regulator upon request.

Notice to California Residents: As a federally-regulated provider of financial services, IBKR is broadly exempt from the California Consumer Privacy Act ("CCPA"). Personal information we collect from clients and prospective clients is protected under separate federal legislation. Over the past 12 months, the only type of information we have collected potentially subject to the CCPA is web-browsing information regarding passive visitors to our website who are California residents, but are not our clients and do not provide us with any specific personal information (name, email address, street address, social security number, etc.) to request information about our services, start an account application or become a client. Information collected from these anonymous, passive visitors to our website may include IP address and browser-specific tags. We do not sell this information to third parties. We only use this information for internal purposes, such as to determine which advertisements are working and which content on our website is most interesting to visitors. Under the CCPA, California residents connected to this type of web-browsing data have a right to request access to it or request that it be deleted. However, we are unable (and not required) to process such requests because we cannot connect such passive web-browsing information collected with an email address or other personal information that we can use to verify that a requesting party is in fact connected to a specific web-browser or IP address.

Updates to this Privacy Policy

This Privacy Policy was last updated on the date indicated at the top of this Policy. We reserve the right to update and change this Privacy Policy from time to time, for example, in order to reflect any changes to the way in which we process your Personal Information or changing legal requirements. In case of any such changes, we will post the changed Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on our website.

How to contact us

We welcome your views about our website and our Privacy Policy. If you have any questions about this Policy, please contact the Data Protection Officer at dpo@ibkr.com or please contact IBKR Client Services through the IBKR website at ibkr.com/help.

Interactive Brokers Business Continuity Plan Disclosure

In accordance with applicable regulations, Interactive Brokers ("IBKR") has developed a Business Continuity Plan ("BCP") to assist the firm in promptly addressing and responding to the possibility of a future Significant Business Disruption ("SBD"). This plan is designed to mitigate or eliminate the impacts of SBDs of varying scope and heighten IBKRs overall operational resilience.

IBKR's BCP was developed using a risk-based approach to identify critical business activities, systems, data and functions and determine the means by which customers will be provided prompt access to their funds and accounts in the event of an SBD. Additionally, the plan describes resiliency and redundancy controls implemented within the systems infrastructure to minimize the potential adverse effects of a disruption.

IBKR's BCP is designed to restore client access to the systems which service funds and positions within 24 hours of a disruption, although recovery time can vary depending on the nature of the disruption, the specific services that have been disrupted or factors outside of IBKR's control.

Key elements of IBKR's BCP include:

1. Alternate physical meeting locations.

   IBKR employees receive procedures and training on what to do and where to go in the event of an SBD, including physical meeting locations away from the impacted office space. These instructions may vary depending on the nature and scope of the disruption.

2. Geographically diverse resources.

   IBKR has designed its systems, procedures and personnel structure to include significant redundancy and cross-capability in the event of a disaster or disruption impacting its Headquarters or one of its primary data centers. These system redundancies allow disruptions affecting communications lines, computer hardware components, or systems to be addressed as promptly as possible.

   Additionally, IBKR operations are supported by a global workforce. Should a disruption occur that is localized to a specific geographic location, IBKR staff around the world are available to work with clients via chat, email or telephone. IB back office staff from other locations can generally provide support in the event of a localized disruption.

3. An infrastructure in place to support all key staff working remotely.

   As an online broker, IBKR is naturally well positioned to continuously operate in the event that physical locations become compromised due to a disruption. IBKR has a robust infrastructure in place to support all key staff working remotely should office locations, including IBKR Headquarters, be unavailable.

4. Detailed communication plans to keep staff and customers informed during a disruption.

   Disruptions are often dynamic events that can change moment to moment. During the course of a disruption, IBKR provides staff with updates through various channels such as email, telephone, or instant messaging.

   In addition, the BCP is reviewed with IBKR staff no less than annually to ensure that staff are well aware of what to do in the event of a disruption, and how they may receive updates as a situation unfolds.

Notice Regarding USA Patriot Act Section 311

Pursuant to U.S. regulations issued under Section 311 of the USA PATRIOT Act, Interactive Brokers will require additional special measures for customers establishing, maintaining, administering or managing an account for, or on behalf of any Section 311 entities. The most recent listing of 311 entities as promulgated by FinCEN, as of March 30, 2021, is as follows:

• Al-Huda Bank
• Bank of Dandong
• Any bank or financial institution of Burma
• Bitzlato
• Commercial Bank of Syria (includes Syrian Lebanese Commercial Bank)
• Any bank or financial institution of the Democratic People's Republic of Korea
• FBME Bank Ltd.
• Halawi Exchange Co.
• Any bank or financial institution of the Islamic Republic of Iran
• Kassem Rmeiti & Co for Exchange
• PM2BTC

Any customers involved with 311 entities will be subject to further review and determination on whether Interactive Brokers will continue the relationship. Additionally, your account with Interactive Brokers may not be used to provide services for the above that would violate other U.S. regulations.

Interactive Brokers may, from time to time, update this notice to include jurisdictions or entities that are added to FinCEN's Section 311 list. Current listings of entities subject to final or proposed rules under Section 311 can be found on the FinCEN website.

RISK DISCLOSURE REGARDING COMPLEX OR LEVERAGED EXCHANGE-TRADED PRODUCTS

Interactive Brokers ("IBKR") is furnishing this disclosure to clients to provide additional information regarding the characteristics and risks associated with Complex or Leveraged exchange-traded products ("ETPs"). Complex or Leveraged Exchange-Traded Products ("ETPs") are funds or notes that trade on an exchange but have very different characteristics from shares of stock or ordinary exchange-traded funds (ETFs) such as an S&P 500 Index ETF. Complex or Leveraged ETPs may include, but are not limited to: (1) leveraged ETFs and ETPs; (2) inverse ETFs and ETPs; (3) volatility-linked ETFs and ETPs; (4) Exchange-Traded Notes ("ETNs"); (5) cryptocurrency ETFs and ETPs; and (6) any other ETP that uses derivatives, that contains imbedded leverage, or that is based on an exotic or volatile underlying commodity or index or financial product.

In addition to providing this disclosure, IBKR strongly encourages clients to carefully review the prospectus, Key Information Document or other available disclosures relating to the specific ETF, ETN or other ETP before investing, to understand its unique features, risks, fees, tax treatment and other characteristics.

LEVERAGED FUNDS

As the name implies, leveraged mutual funds and ETFs seek to provide leveraged returns at multiples of the underlying benchmark or index they track. Leveraged funds generally seek to provide a multiple (i.e., 200%, 300%) of the daily return of an index or other benchmark for a single day excluding fees and other expenses. In addition to using leverage, these funds often use derivative products such as swaps, options, and futures contracts to accomplish their objectives. The use of leverage as well as derivative instruments can cause leveraged funds to be more volatile and subject to extreme price movements, potentially causing rapid losses.

INVERSE FUNDS

Inverse mutual funds and ETFs, which are sometimes referred to as "short" funds, generally seek to provide the opposite of the single day performance of the index or benchmark they track. Inverse funds are often marketed as a way to profit from, or hedge exposure to, downward moving markets. Some inverse funds also use leverage, such that they seek to achieve a return that is a multiple of the opposite performance of the underlying index or benchmark (i.e., -200%, -300%). In addition to leverage, these funds may also use derivative instruments to accomplish their objectives. As such, inverse funds are volatile and entail the potential for significant losses.

VOLATILITY-LINKED PRODUCTS

Volatility-linked ETPs are generally designed to track a volatility measure, typically the Chicago Board Options Exchange Volatility Index (VIX) futures. The VIX is a measure of the expected volatility of the S&P 500 index as measured by the implied volatility of options on that index. Volatility ETPs gain exposure to market volatility through futures and/or options contracts on the VIX. Volatility-linked ETPs that seek to maintain a continuous, targeted maturity exposure to VIX futures will either track or hold VIX futures contracts on a rolling basis. They will sell shorter-term contracts or contracts about to expire and replace them with contracts that have more distant or deferred maturity dates in order to maintain the desired exposure. The performance of volatility-linked ETPs may be significantly different than the performance of the VIX and the actual realized volatility of the S&P 500 Index. VIX futures contracts are among the most volatile segments of all futures markets. Volatility-linked ETPs may be subject to extreme volatility and much greater risk of loss than other traditional ETFs.

EXCHANGE-TRADED NOTES

ETNs are a type of debt security that trade on exchanges and promise a return linked to a market index or other benchmark. ETNs are unsecured debt obligations of the issuer-typically a bank or another financial institution. Unlike traditional bonds, ETNs typically do not pay any interest payments to investors. Instead, the issuer promises to pay the holder of the ETN an amount determined by the performance of the underlying index or benchmark on the ETN's maturity date (typically 10, 30 or in some cases even 40 years from issuance), minus any specified fees. In addition, unlike traditional bonds, ETNs trade on exchanges throughout the day at prices determined by the market, similar to stocks or ETFs. But unlike ETFs, ETNs do not buy or hold assets to replicate or approximate the performance of the underlying index.

Some ETNs provide exposure to familiar, broad-based indexes, while others do so to less familiar asset classes or newer, more complex, or even proprietary indexes. For example, there are ETNs linked to indexes that track emerging markets, commodities such as gold and oil, foreign currencies and market volatility. Some of the indexes and investment strategies used by ETNs can be quite sophisticated and may not have much performance history. The return on an ETN generally depends on price changes if the ETN is sold prior to maturity (as with stocks or ETFs)-or on the payment, if any, if the ETN is held to maturity or redeemed (as with some other structured products).

Some ETNs offer leveraged exposure to the index or benchmark they track. This means that they promise to pay a multiple of the performance of the underlying index or benchmark. For example, an ETN that offers two times-or "2x"-leverage promises to pay twice the performance of the index it tracks.

Inverse ETNs offer to pay the opposite of the performance of the index or benchmark they track, and leveraged inverse ETNs seek to pay a multiple of the opposite of the performance of the index or benchmark they track. Some leveraged, inverse or leveraged inverse ETNs are designed to achieve their stated performance objectives on a daily basis and "reset" their leverage or inverse exposure on a daily basis. Given the daily resetting of its leverage factor, an ETN that is set up to deliver twice the performance of a benchmark on a daily basis will not necessarily deliver twice the performance of that benchmark over longer periods such as weeks, months or years. Due to the effect of compounding, their performance over longer periods of time can differ significantly from the stated multiple of the performance (or inverse of the performance) of their underlying index or benchmark during the same period of time.

Generally, leveraged and inverse ETNs are designed to be short-term trading tools and are not intended for buy-and-hold investing. Other leveraged, inverse or leveraged inverse ETNs can have monthly resets or even no resets, so it is important to distinguish one type from another and understand how their performance may differ.

ETNs list on an exchange and can be bought and sold at market prices, similar to other exchange-traded investments. Market prices of ETNs may fluctuate due to movements in the indexes they track, as well as other factors, including ETN issuances and redemption activity. Issuers of ETNs issue and redeem notes as a means to keep the ETN's price in line with a calculated value, called the indicative value or closing indicative value for ETNs. This value is calculated and published at the end of each day by the ETN issuer. When an ETN is trading at a premium above the indicative value, issuing more notes to the market can bring the price down. Similarly, if an ETN is trading at a discount, redemption of notes by the issuer reduces the number of notes available in the market, which tends to raise the price.

ETN issuers have primary control over the issuance and redemption processes in the ETN market. The decision to issue additional notes is at the issuer's sole discretion. Investors may initiate the redemption process prior to an ETN's maturity date, following precise steps laid out by the issuer in the prospectus. The process generally begins by submitting a "notice of redemption" form to the issuer. Given the various steps in the process, transaction fees-and especially the large number of ETNs required to initiate a redemption (usually 25,000 or 50,000)-redemption is not generally a practical source of liquidity for most retail investors. If a redemption occurs, the issuer will redeem the notes at the ETN's indicative value.

Indicative values are generally based on the value of the underlying index or benchmark, minus certain fees (sometimes referred to as "daily investor fees"), which vary across ETNs and can fluctuate for a given ETN. ETNs also typically have an intraday indicative value that is calculated and published every 15 seconds during the trading day under the applicable trading symbol by the market in which the ETN trades. Each ETN uses its own formula for computing its indicative value, which is generally outlined in the ETN's prospectus or pricing supplement.

An ETN's closing indicative value, as well as its intraday indicative value, are distinct from an ETN's market price, which is the price at which an ETN trades in the secondary market. In theory, an ETN's market price should closely track its closing and intraday indicative values. However, an ETN's market price can deviate, sometimes significantly, from its indicative value. Price deviations can happen for a variety of reasons; for example, an ETN might trade at a premium to its indicative value if the issuer suspends issuance of new notes.

Paying a premium relative to the indicative value to purchase the ETN in the secondary market and then selling the ETN when the market price no longer reflects the premium can lead to significant losses for an investor. There have been previous occasions when an ETN experienced price movements that diverged significantly from its indicative value and the performance of the index it tracks, due in part to suspensions in the issuance of new notes, which caused the ETN to trade at significant premiums. When the issuer of the ETN subsequently resumed the issuance of new notes, the market price of the ETN then fell sharply, dropping by more than half in two days.

CRYPTOCURRENCY-LINKED ETPs

Cryptocurrency linked ETPs are designed to provide exposure to one or more cryptocurrencies. These products may invest directly in cryptocurrencies by buying and selling them in the cash market, or they may invest in cryptocurrency futures contracts (or options on such futures contracts) by trading them on futures exchanges.

ETPs that trade cryptocurrencies on cash markets expose investors to risks associated with those markets, which may include:

• extreme price volatility;
• risk that these cash markets or specific cryptocurrencies may become illiquid;
• lack of regulation or supervision by a government agency;
• risk of manipulation; and
• a lack of critical system safeguards, which may give rise to risks associated with hacking or "flash crashes".

Cryptocurrency futures contracts are bought and sold using leverage. If the price of the futures contract moves in an unfavorable direction, the leveraged nature of the investment can produce large losses. Cryptocurrency futures contract prices are impacted by many of the same risks that are associated with prices in the cash markets. The use of leverage amplifies the impact of the occurrence of an adverse event in the cash markets and means that the same event may produce greater losses in an ETP that invested in cryptocurrency futures than an ETP that invested directly in the underlying cryptocurrency. But ETPs that invest in futures may not be subject to the same risks of loss related to hacking, or theft or loss of the cash cryptocurrency.

These characteristics, as well as the novelty of cryptocurrencies and cryptocurrency ETPs, subject investors in these products to a far greater risk of loss than is associated with ETPs that invest in traditional securities or commodities.

RISKS ASSOCIATED WITH COMPLEX OR LEVERAGED ETPS

Complex or Leveraged ETPs are complicated instruments that should only be used by sophisticated investors who fully understand the terms, investment strategy and risks associated with the funds. In particular, clients should be aware of certain specific risks involved. These risks include, but are not limited to:

Use of Leverage and/or Derivative Instruments: Many leveraged and inverse funds as well as volatility-linked products use leverage and derivative instruments, such as futures and options contracts, to achieve their stated investment objectives. As such, they can be extremely volatile and carry a high risk of substantial losses. Complex or Leveraged ETPs are considered speculative investments and should only be used by investors who fully understand the risks and are willing and able to absorb potentially significant losses.

Seek Daily Target Returns: Many Complex or Leveraged ETPs "reset" daily, meaning that they are designed to achieve their stated objectives on a daily basis. Due to the effect of compounding, the return for investors who invest for a period longer than one trading day may vary significantly from the stated goal as well as the target benchmark's performance. This is especially true in very volatile markets or if an ETP is tracking a very volatile underlying index. Investments in any ETP must be actively monitored on a daily basis and are typically not appropriate for a buy-and-hold strategy.

Higher Operating Expenses and Fees: Investors should be aware that these ETPs typically rebalance their portfolios on a frequent basis, often daily, in order to compensate for anticipated changes in overall market conditions. For example, volatility-linked ETPs will rebalance their exposure to futures of different maturities to maintain the targeted maturity. This rebalancing can result in frequent trading and increased portfolio turnover. These ETPs will therefore generally have higher operating expenses and investment management fees than other funds or products.

Tax Treatment May Vary: In many cases, Complex or Leveraged ETPs may generate their returns through the use of derivative instruments. Because derivatives are taxed differently from equity or fixed-income securities, investors should be aware that these ETPs may not have the same tax efficiencies as other funds or products.

Credit Risk: ETNs are unsecured debt obligations of the issuer. If the issuer defaults on the note, investors may lose some or all of their investment.

Market Risk: ETPs are market-linked: the value of an ETP is largely influenced by the value of the index it tracks or underlying investments it is based on. Make sure you understand what underlying or index is being tracked by the ETP-for example, some indices reflect a dynamic trading strategy and others are based on futures markets. Also, some indices reflect "total returns" while others may not.

Liquidity Risk. Although ETPs are exchange-traded, they do carry some liquidity risk. As with other exchange-traded products, a trading market may not develop. In addition, under some circumstances, issuers can delist an ETP. If this happens, the market for the ETP can dry up or evaporate entirely.

• Price-Tracking Risk. ETPs typically trade at prices that closely track their indicative values, but this might not always be the case. When trading in the secondary market, check market prices against indicative values, and be wary of buying at a price that varies significantly from closing and intraday indicative values.
• Holding-Period Risk. Some ETPs, particularly some leveraged, inverse and inverse leveraged ETNs, are designed to be short-term trading tools (with holding periods as short as one day) rather than buy-and-hold investments. Because of the effects of compounding, the performance of these products over long periods can differ significantly from the stated multiple of the performance (or inverse of the performance) of the underlying index or benchmark during the same period.
• Call, Early Redemption and Acceleration Risk. Some ETNs are callable at the issuer's discretion. In some instances ETNs can be subject to early redemption or an "accelerated" maturity date at the discretion of the issuer or one of its affiliates. Since ETNs may be called at any time, their value when called may be less than the market price that you paid or even zero, resulting in a partial or total loss of your investment.
• Conflicts of Interest. There are a number of potential conflicts of interest between you and the issuer of these products. For example, the issuer of ETNs may engage in trading activities that are at odds with investors who hold the notes (shorting strategies, for instance). Search the ETN's prospectus for any mention of "conflicts of interest" and evaluate whether these conflicts are worth the risk.

BEFORE YOU INVEST

Make sure you have answers to the following questions so that you can better assess whether an ETP investment is right for you:

• Who is the issuer? Once you know, be sure to research the issuer's credit rating and financial situation. If the issuer is publicly traded, use the SEC's EDGAR database. Keep in mind that for ETNs, they are not registered investment companies and therefore are not subject to the same registration, disclosure and other regulatory requirements as most ETFs or mutual funds.
• What index or benchmark does the ETP track? If it involves an unfamiliar market or asset class, ask yourself whether you feel informed enough about the market or asset to effectively assess the risks involved.
• Is the ETP callable by the issuer? You can find this out by reading the prospectus or asking your financial professional.
• Does the ETP offer leveraged or inverse exposure to the underlying index or benchmark? If so, how frequently does it "reset"? One clue may be in the ETP's name: words like "daily" and "short-term" often indicate that the product resets daily and is not intended to be held for long periods of time.
• What fees and costs are associated with the ETP? ETPs differ widely with respect to fees, including the investor fee charged in connection with redemptions. Read the prospectus and ask your investment professional to clearly explain any fees and expenses associated with a given ETN.
• What are the tax consequences? The tax treatment of ETPs can vary depending on the nature of the ETN. Check with your tax advisor if you are unsure about the tax implications of a particular investment.
  

INTERACTIVE BROKERS FRACTIONAL SHARE TRADING DISCLOSURE

Interactive Brokers ("IBKR") allows its brokerage clients, directly or through their independent investment advisor or Introducing Broker (including affiliates of IBKR), to purchase certain stocks and ETFs (where available) ("Shares") in fractional Shares rather than whole Share quantities. This disclosure outlines the unique features, limitations, and risks associated with trading in and holding fractional Shares.

Capacity - In connection with any fractional Share component of any purchase or sale transaction, an IBKR affiliate will generally act as a counterparty and will execute that portion of the trade as principal or riskless principal. Orders for whole shares will continue to be handled in an agency capacity except where executed by an IBKR affiliate, in which case the IBKR affiliate will act as principal. The client will always be the beneficial owner of any fractional Shares in their account and all fractional Shares owned by a client are segregated in IBKR's books and records in the same manner and to the same extent as whole shares owned by such client.

Transfer of Fractional Shares - While clients maintain complete day-to-day control of any fractional Shares in their account, fractional shares are not transferable to another broker. If a client wants to transfer the holdings in an account to another brokerage firm, the fractional Share holdings cannot be transferred and will need to be liquidated before transfer, which may have tax consequences and will result in commission charges. To effect a request for a transfer, IBKR will purchase the fractional Shares from the client's account using the pricing mechanism described above and charge commissions on these closing trades, then transfer the remaining whole Share quantities.

Insolvency - In the unlikely event IBKR becomes insolvent, clients will still hold their fractional interest. However, if the appointed insolvency practitioner (or administrator/liquidator) cannot transfer fractional entitlements to another broker (or custodian) they may need to liquidate (sell) the fractional interest and return the monetary value to the client instead.

Available Order Types - IBKR will only accept certain types of orders for fractional Shares (e.g., market orders, limit orders, stop orders, stop limit orders, etc.). In the event that a client chooses to place a non-marketable limit order with a fractional Share component, the fractional component may not execute until the order becomes marketable (and therefore may not execute at all), even if the fractional Share component of the order might have executed earlier if submitted for a whole Share quantity. Please contact us if you have any questions about order types available for fractional trading.

Voting Rights - Clients will not have voting rights for any of the fractional Shares held in their account, will not be able to make voluntary elections on any corporate action (including, without limitation, any tender offers or rights offerings) with respect to such fractional Shares, and IBKR cannot provide clients any other shareholder documentation for any holdings of less than one Share. Clients will, however, receive payments of dividends, or in some cases in connection with stock dividends, either dividend shares or value commensurate to the dividend Shares, and will otherwise participate normally in any stock splits, mergers or other mandatory corporate actions.

Four-Decimal Place Recording - IBKR records the quantity of fractional Shares traded or otherwise held in a brokerage account down to four decimal places.

Risk Disclosure for Trading Digital Assets with Paxos Trust Company Through IBKR's Platform

Important Information Regarding Trading Digital Assets with Paxos

Interactive Brokers LLC ("IBKR") offers clients the ability to access digital asset trading and custody services (the "Paxos Services") in an account in client's name (the "Paxos Account") at Paxos Trust Company ("Paxos") through IBKR's electronic trading software. The digital assets in your Paxos Account are carried at Paxos while all other assets are carried in your IBKR account. Fiat currency is carried in your IBKR account and may also be carried in your Paxos Account if you designated that account as your source of payment for digital asset purchases pursuant to the Supplement to Interactive Brokers LLC Client Agreement in Connection with Trading Digital Assets with Paxos Trust Company Through IB’s Platform (“Payment Source Account”) and moved fiat currency into that account in anticipation of purchasing digital assets. You should carefully consider the risks below before making a decision to utilize the Paxos Services.

1. Trading Of Digital Assets is Risky. Digital asset prices are highly volatile and can rise or fall dramatically and quickly. If you hold a position in digital assets and the value of the asset falls, you can lose money. You should carefully consider your financial circumstances and your risk tolerance before trading digital assets with Paxos and you should not trade digital assets unless you have the financial capability to sustain losses if they occur. You should be aware that you may sustain a total loss of the assets in your Paxos Account.
2. No Investment Advice, Recommendations, Or Tax Advice. IBKR does not provide investment, tax, or trading advice or recommendations. By making digital assets available to you, neither IBKR nor Paxos makes any assessment, representation, or warranty concerning the appropriateness or suitability of digital assets for your financial circumstances. The Paxos Services are "execution only." IBKR and Paxos will not advise you on any transaction. Neither IBKR nor Paxos will assess whether your transactions are suitable for you or help you avoid losses. You should obtain your own financial, legal, taxation, and other professional advice as to whether digital assets are appropriate investments for you.
3. Digital Asset Holdings Are Not Covered By FDIC or SIPC. In general, US broker-dealers cannot custody non-securities digital assets. Therefore, US brokers seeking to offer their clients the ability to trade digital assets must work with another entity (a "Crypto Broker/Custodian") which is suitably licensed, and at which clients trading digital assets have separate accounts in their own name. These Crypto Broker/Custodians are not broker-dealers, and so SIPC coverage does not apply to accounts at Crypto Broker/Custodians. Likewise, most Crypto Broker/Custodians are not insured banks, and digital assets are not cash, so FDIC coverage does not apply to digital assets held in accounts at Crypto Broker/Custodians.
   
   IBKR has selected Paxos as the Crypto Broker/Custodian with which to work. By requesting trading permissions for digital assets through IBKR's platform, you are opening an account in your name at Paxos (the previously mentioned Paxos Account). All trading you do in digital assets through IBKR's platform will be executed in your Paxos Account (and not an account at IBKR), and Paxos will be your custodian and counterparty for those trades, which means that Paxos holds your digital assets for you and represents your ownership of them on their internal ledger. As explained above, the holdings in your Paxos Account are not protected by FDIC or SIPC insurance in the event of Paxos' or IBKR's insolvency.
   
   Notwithstanding the above, because IBKR is a member of the National Futures Association (the "NFA"), IBKR is required to provide you with the following disclosure in connection with trading digital assets / "virtual currencies":
   
   INTERACTIVE BROKERS LLC IS A MEMBER OF NFA AND IS SUBJECT TO NFA'S REGULATORY OVERSIGHT AND EXAMINATIONS. HOWEVER, YOU SHOULD BE AWARE THAT NFA DOES NOT HAVE REGULATORY OVERSIGHT AUTHORITY OVER UNDERLYING OR SPOT VIRTUAL CURRENCY PRODUCTS OR TRANSACTIONS OR VIRTUAL CURRENCY EXCHANGES, CUSTODIANS OR MARKETS.
   
   
4. Trading Hours May Be Limited; Paxos Web Interface; Stop Loss Orders. Digital assets generally trade 24/7, and their prices may change dramatically over the weekend. But your ability to access your Paxos Account through IBKR's platform, including purchasing or selling digital assets over the weekend, may be limited. Please visit IBKR's public website for additional detail on trading hour limitations.
   
   To mitigate this risk, Paxos will make available to you at https://ibkr.paxosclients.com/, on a best-efforts-basis, a separate web-based interface (the "Paxos Web Interface"). Through the Paxos Web Interface, you can view digital asset positions at any time, and you can place orders to close (or reduce) positions in digital assets at times when IBKR's platform is unavailable for trading. If you have designated your Paxos Account as your Payment Source Account, you may also place buy orders directly with Paxos through the Paxos Web App, subject to the requirement that buy orders must be fully funded (including commission) when placed.
   
   Paxos may offer stop and/or stop-limit orders (generally, "stop-loss orders") that you may choose to use to manage your risk, with respect to sudden decreases in the value of digital assets in your Paxos Account.
   
   A stop order is an order to buy or sell a digital asset once the price of the digital asset reaches a specified price (the "stop price"). When the stop price is reached, a stop order becomes a market order and can execute at any price (not necessarily at the stop price). A sell stop order is entered at a stop price below the current market price. Investors generally use a sell stop order to limit a loss or to protect a profit on a digital asset that they own.
   
   A stop-limit order is an order to buy or sell a stock that combines the features of a stop order and a limit order. Once the stop price is reached, a stop-limit order becomes a limit order that will be executed (if possible) at a specified price (or better). Like a regular limit order, stop-limit orders will only execute if there is liquidity at your limit price or a better price.
   
   In a quickly falling market, including in situations where many customers submit stop orders with a similar stop price, or when there is a lack of liquidity in the market, a stop order may execute a significant amount away from the specified stop price and a stop-limit order may not execute at all.
   
   Stop and stop-limit orders, while outstanding, are eligible to execute even outside of the times when IBKR's platform is available for trading.
   
   Using stop orders carries its own risks, including that your order may execute at an unfavorable price, and that the price of the digital asset may subsequently rise sharply above the level of the stop price, and you could lose money if you then reestablish your position at a price above the price at which you exited it as a result of your stop-loss order executing.
5. Digital Asset Purchases Must Be Fully Funded When Orders Are Submitted. You are responsible for ensuring that there is sufficient cash available in your designated Payment Source Account to fully fund your purchase of digital assets at the time you submit an order. If you have designated your Paxos Account as your Payment Source Account, you are responsible for transferring cash from IBKR to Paxos before placing a buy order. If you have designated your IBKR brokerage account as your Payment Source Account, IBKR will transfer cash from your IBKR brokerage account to Paxos when you execute a trade to purchase digital assets. Orders that are not fully funded will be rejected.
6. The Digital Asset Market Is Highly Speculative And Extremely Volatile. The market for digital assets can be extremely volatile. The price of digital assets may be influenced by, among other things, the performance of the economy as a whole; new or amended government regulation; the changing supply and demand relationships for digital assets; governmental, commercial and trade programs and policies; interest rates; technological developments; inflation; national and international political and economic events; statements by internet celebrities; social media sentiment; and the prevailing psychological characteristics of the relevant marketplace.
7. Digital Assets Custodied with Paxos Will Have No Margin Value In Your IBKR Account. The assets (whether digital or cash) custodied in your Paxos Account will not be assigned any margin value. Such digital assets will not be considered in determining your IBKR account's compliance with either securities or commodities margin requirements. If you have insufficient equity in your IBKR account to meet your margin requirements, the assets in your IBKR account may be liquidated.
8. Digital Assets Carry Liquidity Risk. Paxos is not obligated to provide quotes for digital assets at any time, and neither Paxos (nor IBKR) guarantee the continuous availability of quotations or trading for digital assets on Paxos' or any other digital asset exchanges. Paxos may in its sole discretion cease quoting digital assets and/or cease entering new digital asset transactions at any time.
9. You Will Pay Commissions For Trading Digital Assets. Paxos will charge commissions on your digital asset trades. For more details on the commissions, please see https://www.interactivebrokers.com/en/index.php?f=1590.
10. Your Agreement with Paxos Governs Your Paxos Account. Your Paxos Account is governed by the Paxos Exchange Terms & Conditions ("Paxos T&Cs"). You should read the Paxos T&Cs carefully and understand the terms of your relationship with Paxos.
11. You Are Not Permitted To Short Digital Assets. Short sales of digital assets are prohibited. The inability to open short digital asset positions may negatively impact your ability to protect against trading losses.
12. The Digital Assets Available to You Are Limited and Subject to Change. The digital assets available for trading in your Paxos Account are limited. Paxos or IBKR may further limit the available digital assets to be traded on the IBKR platform at their own discretion and without prior notice to you. A complete list of available digital assets that may be purchased in your Paxos Account through IBKR's platform is available at https://www.interactivebrokers.com/lib/cstools/faq/#/content/182856890.
13. Risk Of Disruption Or Interruption Of Access To Paxos Account. Both IBKR and Paxos rely on computer software, hardware and telecommunications infrastructure and networking to provide their respective services to you, and without these systems neither can provide you with access to your respective accounts. These computer-based systems and services such as those used by Paxos are inherently vulnerable to disruption, delay or failure, which may cause you to lose access to the IBKR trading platform and thereby your Paxos account or may cause IBKR or Paxos not to be able to provide digital asset quotations or trading, or may negatively affect any or all aspects of Paxos' services. Under the IBKR Client Agreement, you accept the IBKR systems and services "As-ls" and IBKR's liability to you is limited.
14. Other Important Information Covered by Paxos Terms & Conditions. If at any time you wish to transfer some or all of your digital asset holdings in your IBKR-linked Paxos account out of your IBKR-linked Paxos account and into an independent Paxos account (from which you can then continue to freely trade such assets or transfer them to other addresses on the blockchain), please see the Paxos Terms & Conditions for instructions on how you may do so. In the event that IBKR ceases operations, Paxos will contact you to transfer the holdings in your IBKR-linked account to an independent account, in accordance with the Paxos Terms & Conditions.

PRC RESIDENT PIPL ACKNOWLEDGEMENT & SEPARATE CONSENTS

I/We acknowledge that:

• Interactive Brokers and its affiliates ("IBKR") may obtain information (including personal information and sensitive personal information, each as defined in the Personal Information Protection Law of the People's Republic of China ("PIPL") about me/us or my/our directors, shareholders, employees, officers, agents or clients as necessary. IBKR shall comply with applicable data protection laws with regards to processing personal data. I/We acknowledge that I/we have read and understood the Interactive Brokers Group Privacy Policy published on www.interactivebrokers.com (as may be updated from time to time) which sets out how personal data shall be processed by IBKR.
• IBKR may use, store or otherwise process any such information (whether provided electronically or otherwise) and may disclose any such information (including, without limitation, information relating to my/our transactions and account) either as IBKR shall be obliged to under or pursuant to any applicable law or rules or by any regulatory authority or as may be required to provide services to me/us under the client agreement with IBKR ("Agreement").
• IBKR may:
  • disclose information about me/us to my/our agents or attorneys for any purpose relating to the Agreement;
  • disclose information about me/us and my/our clients, of a confidential nature, in the circumstances set out in this clause:
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    • as may be required for the purposes set out in this clause.
  • To the extent any consent or authorization is required by law, I/we hereby consent and authorize IBKR, directly or through third parties, to make any enquiries in relation to my personal data that IBKR considers necessary to conduct business with me/us. This may include ordering a credit report and performing other credit checks, or verifying the information I/we provide against third party databases. I/We acknowledge that any personal data obtained is maintained in accordance with the Interactive Brokers Group Privacy Policy.

PRC RESIDENT PIPL ACKNOWLEDGEMENT - COLLECTION OF SENSITIVE PERSONAL INFORMATION

I/We acknowledge and agree to give IBKR separate consent to obtain sensitive personal information (as defined in the Personal Information Protection Law of the People's Republic of China ("PIPL"), including financial information, about me/us or my/our directors, shareholders, employees, officers, agents or clients as necessary to provide services to me/us under the client agreement with IBKR.

For more information on how IBKR may use, store, or otherwise process client information, please refer to the Interactive Brokers Group Privacy Policy for details and contact information.